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Ex parte Bradley Thomas

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Case Information
Case name Ex parte Bradley Thomas[1]
Court Texas Second Court of Appeals, Fort Worth[1]
Docket 02-26-00039-CR (appeal); CR-2020-01729-A-WHC (trial court)[1]
Filed Appeal filing date not identified in the opinion reviewed[1]
Judge(s) Opinion by Justice Wade Birdwell; Chief Justice Sudderth and Justice Walker on the panel[1]
Appellant / applicant Bradley Wayne Thomas, appellant and habeas applicant[1]
Appellee State of Texas, appellee[1]
Case type Criminal post-conviction habeas appeal under Texas Code of Criminal Procedure article 11.072[1]
Claims / issues Whether the denial of habeas relief could be challenged on appeal; the appellate court addressed inadequate briefing, including apparently AI-assisted and inaccurate citations[1]
Status September 24, 2026: appellate court affirmed denial of habeas relief after holding Thomas forfeited his appellate complaints through inadequate briefing[1]

Ex parte Bradley Thomas concerns a self-represented appeal from the denial of a Texas habeas application following a misdemeanor family-violence assault conviction. On September 24, 2026, the Texas Second Court of Appeals affirmed the denial because Bradley Thomas did not adequately brief his appellate complaints. The court said he appeared to have used AI to prepare the brief, but its decision rested on the briefing deficiencies and did not establish that he used a particular tool.[1]

Proceedings and opinion

Thomas sought habeas relief after the same appellate court affirmed his conviction on direct appeal. The trial court denied his application without a hearing. His amended appellate brief attempted to challenge the evidentiary record, trial and appellate counsel, and the habeas procedure, among other matters.[1]

The appellate court held that the brief's arguments were confusing and lacked substantive analysis and adequate citations to authorities and the record. It identified purported authorities that did not exist or were cited inaccurately, quotations not supported by the cited cases, and assertions that misrepresented the record. The court said Thomas may have used ChatGPT or another AI tool and cautioned litigants about relying on such tools to prepare filings. It treated the claims as forfeited under Texas appellate briefing rules and affirmed the order denying habeas relief without deciding the underlying habeas claims on their merits.[1]

References