ACCEPTED 15-25-00217-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 11/25/2025 3:53 PM CHRISTOPHER A. PRINE IN THE FIFTEENTH COURT OF APPEALS CLERK AT AUSTIN, TEXAS FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 11/25/2025 3:53:47 PM CASE NO. 15-25-00217-CV CHRISTOPHER A. PRINE Clerk (Transferred from the Third Court of Appeals)
CEDRIC M. SCOTT, PhD Appellant, Pro Se
v.
GENERAL LAND OFFICE OF THE STATE OF TEXAS Appellee
On Appeal from the 250th Judicial District Court of Travis County, Texas Trial Court Cause No. D-1-GN-25-000006
APPELLANT’S MOTION FOR SANCTIONS AGAINST GLO FOR FILING A FRIVOLOUS MOTION TO DISMISS
Respectfully submitted,
/s/ Cedric M. Scott Cedric M. Scott, PhD 901 Hidden Valley Drive, #9204 Round Rock, Texas 78665 cedricscott41@gmail.com
Appellant, Pro Se TO THE HONORABLE FIFTEENTH COURT OF APPEALS:
Appellant, Cedric M. Scott, PhD1, respectfully moves for sanctions against
the General Land Office (“GLO”) pursuant to Tex. R. App. P. 45, Tex. Civ. Prac. &
Rem. Code Chapter 10, and this Court’s inherent authority, and states as follows:
I. INTRODUCTION
GLO’s Motion to Dismiss is legally frivolous, factually unsupported, and
procedurally improper. It relies on rulings issued by a disqualified trial judge, seeks
affirmative appellate relief while GLO remains in procedural default, and
misrepresents that Appellant “agreed” to dismissal based on an informal email sent
before Appellant learned of Judge Liu’s conflict of interest. GLO’s Motion to
Dismiss lacks any basis in law or fact, and because it was filed for the improper
purpose of obscuring structural judicial error and avoiding appellate review,
sanctions are warranted.
II. THE MOTION TO DISMISS IS FRIVOLOUS UNDER TRAP 45
An appellate court may award damages and costs when a party files a
frivolous motion or brief. Tex. R. App. P. 45. A motion is frivolous when:
1. It has no reasonable legal basis,
2. It misstates controlling principles, or
1 Plaintiff’s first name is pronounced See-Drick and not Said-Drick. Gender is female, and pronouns are she, her, and hers.
2 3. A reasonable attorney should know it cannot succeed.
GLO’s arguments depend on orders issued by Judge Cory R. Liu, who was
later discovered to be legally disqualified under Tex. R. Civ. P. 18b(a)(1)(B). A
disqualified judge’s rulings are void ab initio. In re City of Lubbock, 624 S.W.3d
506, 510 (Tex. 2021) and In re Union Pac. Res. Co., 969 S.W.2d 427, 428 (Tex.
1998). Void orders cannot support dismissal, the Motion to Dismiss has no legal
foundation.
III. GLO CANNOT SEEK AFFIRMATIVE RELIEF WHILE IN DEFAULT
GLO never answered Appellant’s Second Amended Petition, filed August
12, 2025, which added new allegations—including cronyism, blacklisting,
conflicts of interest, discovery abuse, and contract-management failures. Under
Tex. R. Civ. P. 62–65, new allegations require a new answer. Stoner v. Thompson,
578 S.W.2d 679, 682 (Tex. 1979), a party that fails to answer is in default and may
not seek any affirmative relief, including:
• Motions to dismiss,
• Motions to compel,
• Discovery orders, or
• Appellate relief.
By filing a Motion to Dismiss despite being in procedural default, GLO
invoked a remedy the law prohibits. This alone renders the Motion frivolous. 3 IV. GLO MISREPRESENTS APPELLANT’S “NON-OPPOSITION” EMAIL
Appellant’s email (dated 10/24/2025) sent weeks before Judge Liu’s recusal and
did not waive any rights because it was:
a. Not filed with the Court,
b. Not a Rule 11 agreement,
c. Not an intentional relinquishment of a known right, and
d. Sent before Appellant discovered the relevance of Judge Liu’s
disqualification.
Therefore, structural judicial errors cannot be waived. Buckholts I.S.D. v. Glaser,
632 S.W.2d 146, 148 (Tex. 1982) and Caperton v. A.T. Massey Coal Co., 556 U.S.
868, 886–87 (2009). GLO’s reliance on this email is misleading and frivolous.
V. SANCTIONS ARE AUTHORIZED UNDER TEXAS LAW
A. TRAP 45 — Frivolous Motions
This Court may award just damages, costs, or “single or double costs”
against a party filing a frivolous appellate motion.
B. Tex. Civ. Prac. & Rem. Code § 10.001–10.006
Sanctions are appropriate where filings are:
1. Submitted for an improper purpose,
2. Legally insufficient, or
3. Without evidentiary support. 4 Low v. Henry, 221 S.W.3d 609, 619 (Tex. 2007) (affirming sanctions for misuse of
judicial process). GLO’s Motion to Dismiss fits all categories mentioned in this
section.
C. Inherent Authority
Courts may sanction conduct that abuses judicial process. In re Bennett, 960
S.W.2d 35, 40 (Tex. 1997). Filing a motion founded on void orders, procedural
default, and misrepresentation of waiver is such abuse. GLO never rejoined issue
and remains in default, which bars any motion to dismiss. Because appellate
jurisdiction depends on a valid order, and because GLO has none, their dismissal
argument cannot stand.
D. Texas Whistleblower Act requires judgment where statutory causation is met
Tex. Gov’t Code §554.004(a):
• If termination occurs within 90 days of a protected report, causation is
presumed as a matter of law. Appellant reported to HUD-OIG and Texas
Rangers and GLO fired her within 90 days. Thus, causation is established.
GLO produced zero rebuttal evidence (because they defaulted). Thus, under the
Act: (a) Liability is established, and (b) Judgment is appropriate.
E. Internal Audit Report 25-01 corroborates your protected activity
GLO’s internal audit report confirms:
• GLO’s longstanding pattern of violations 5 • The exact deficiencies you reported
• Failures involving federal funds, contract oversight, compliance, and
monitoring
This independent government-generated report suffices as objective corroboration
of your whistleblower complaints. Therefore, no contrary evidence exists.
F. Summary Judgment Relief
The Fifteenth Court of Appeals possesses authority to grant judgment in
Appellant’s favor because this record presents the rare situation where the:
1. Trial court never had lawful authority to act,
2. Appellee remains in procedural default, and
3. Material facts are undisputed.
A judge who is disqualified under Tex. R. Civ. P. 18b “is without authority to
act, and any orders issued are void ab initio.” In re City of Lubbock, 624 S.W.3d
506, 510 (Tex. 2021); In re Union Pac., 969 S.W.2d 427, 428 (Tex. 1998).
Thus, every ruling made by Judge Liu—including the denial of Appellant’s
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ACCEPTED 15-25-00217-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 11/25/2025 3:53 PM CHRISTOPHER A. PRINE IN THE FIFTEENTH COURT OF APPEALS CLERK AT AUSTIN, TEXAS FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 11/25/2025 3:53:47 PM CASE NO. 15-25-00217-CV CHRISTOPHER A. PRINE Clerk (Transferred from the Third Court of Appeals)
CEDRIC M. SCOTT, PhD Appellant, Pro Se
v.
GENERAL LAND OFFICE OF THE STATE OF TEXAS Appellee
On Appeal from the 250th Judicial District Court of Travis County, Texas Trial Court Cause No. D-1-GN-25-000006
APPELLANT’S MOTION FOR SANCTIONS AGAINST GLO FOR FILING A FRIVOLOUS MOTION TO DISMISS
Respectfully submitted,
/s/ Cedric M. Scott Cedric M. Scott, PhD 901 Hidden Valley Drive, #9204 Round Rock, Texas 78665 cedricscott41@gmail.com
Appellant, Pro Se TO THE HONORABLE FIFTEENTH COURT OF APPEALS:
Appellant, Cedric M. Scott, PhD1, respectfully moves for sanctions against
the General Land Office (“GLO”) pursuant to Tex. R. App. P. 45, Tex. Civ. Prac. &
Rem. Code Chapter 10, and this Court’s inherent authority, and states as follows:
I. INTRODUCTION
GLO’s Motion to Dismiss is legally frivolous, factually unsupported, and
procedurally improper. It relies on rulings issued by a disqualified trial judge, seeks
affirmative appellate relief while GLO remains in procedural default, and
misrepresents that Appellant “agreed” to dismissal based on an informal email sent
before Appellant learned of Judge Liu’s conflict of interest. GLO’s Motion to
Dismiss lacks any basis in law or fact, and because it was filed for the improper
purpose of obscuring structural judicial error and avoiding appellate review,
sanctions are warranted.
II. THE MOTION TO DISMISS IS FRIVOLOUS UNDER TRAP 45
An appellate court may award damages and costs when a party files a
frivolous motion or brief. Tex. R. App. P. 45. A motion is frivolous when:
1. It has no reasonable legal basis,
2. It misstates controlling principles, or
1 Plaintiff’s first name is pronounced See-Drick and not Said-Drick. Gender is female, and pronouns are she, her, and hers.
2 3. A reasonable attorney should know it cannot succeed.
GLO’s arguments depend on orders issued by Judge Cory R. Liu, who was
later discovered to be legally disqualified under Tex. R. Civ. P. 18b(a)(1)(B). A
disqualified judge’s rulings are void ab initio. In re City of Lubbock, 624 S.W.3d
506, 510 (Tex. 2021) and In re Union Pac. Res. Co., 969 S.W.2d 427, 428 (Tex.
1998). Void orders cannot support dismissal, the Motion to Dismiss has no legal
foundation.
III. GLO CANNOT SEEK AFFIRMATIVE RELIEF WHILE IN DEFAULT
GLO never answered Appellant’s Second Amended Petition, filed August
12, 2025, which added new allegations—including cronyism, blacklisting,
conflicts of interest, discovery abuse, and contract-management failures. Under
Tex. R. Civ. P. 62–65, new allegations require a new answer. Stoner v. Thompson,
578 S.W.2d 679, 682 (Tex. 1979), a party that fails to answer is in default and may
not seek any affirmative relief, including:
• Motions to dismiss,
• Motions to compel,
• Discovery orders, or
• Appellate relief.
By filing a Motion to Dismiss despite being in procedural default, GLO
invoked a remedy the law prohibits. This alone renders the Motion frivolous. 3 IV. GLO MISREPRESENTS APPELLANT’S “NON-OPPOSITION” EMAIL
Appellant’s email (dated 10/24/2025) sent weeks before Judge Liu’s recusal and
did not waive any rights because it was:
a. Not filed with the Court,
b. Not a Rule 11 agreement,
c. Not an intentional relinquishment of a known right, and
d. Sent before Appellant discovered the relevance of Judge Liu’s
disqualification.
Therefore, structural judicial errors cannot be waived. Buckholts I.S.D. v. Glaser,
632 S.W.2d 146, 148 (Tex. 1982) and Caperton v. A.T. Massey Coal Co., 556 U.S.
868, 886–87 (2009). GLO’s reliance on this email is misleading and frivolous.
V. SANCTIONS ARE AUTHORIZED UNDER TEXAS LAW
A. TRAP 45 — Frivolous Motions
This Court may award just damages, costs, or “single or double costs”
against a party filing a frivolous appellate motion.
B. Tex. Civ. Prac. & Rem. Code § 10.001–10.006
Sanctions are appropriate where filings are:
1. Submitted for an improper purpose,
2. Legally insufficient, or
3. Without evidentiary support. 4 Low v. Henry, 221 S.W.3d 609, 619 (Tex. 2007) (affirming sanctions for misuse of
judicial process). GLO’s Motion to Dismiss fits all categories mentioned in this
section.
C. Inherent Authority
Courts may sanction conduct that abuses judicial process. In re Bennett, 960
S.W.2d 35, 40 (Tex. 1997). Filing a motion founded on void orders, procedural
default, and misrepresentation of waiver is such abuse. GLO never rejoined issue
and remains in default, which bars any motion to dismiss. Because appellate
jurisdiction depends on a valid order, and because GLO has none, their dismissal
argument cannot stand.
D. Texas Whistleblower Act requires judgment where statutory causation is met
Tex. Gov’t Code §554.004(a):
• If termination occurs within 90 days of a protected report, causation is
presumed as a matter of law. Appellant reported to HUD-OIG and Texas
Rangers and GLO fired her within 90 days. Thus, causation is established.
GLO produced zero rebuttal evidence (because they defaulted). Thus, under the
Act: (a) Liability is established, and (b) Judgment is appropriate.
E. Internal Audit Report 25-01 corroborates your protected activity
GLO’s internal audit report confirms:
• GLO’s longstanding pattern of violations 5 • The exact deficiencies you reported
• Failures involving federal funds, contract oversight, compliance, and
monitoring
This independent government-generated report suffices as objective corroboration
of your whistleblower complaints. Therefore, no contrary evidence exists.
F. Summary Judgment Relief
The Fifteenth Court of Appeals possesses authority to grant judgment in
Appellant’s favor because this record presents the rare situation where the:
1. Trial court never had lawful authority to act,
2. Appellee remains in procedural default, and
3. Material facts are undisputed.
A judge who is disqualified under Tex. R. Civ. P. 18b “is without authority to
act, and any orders issued are void ab initio.” In re City of Lubbock, 624 S.W.3d
506, 510 (Tex. 2021); In re Union Pac., 969 S.W.2d 427, 428 (Tex. 1998).
Thus, every ruling made by Judge Liu—including the denial of Appellant’s
summary judgment—has no legal effect and cannot bar appellate relief.
VI. REQUESTED RELIEF
Accordingly, because the factual record is conclusive, the Real Party in
Interest is in default, and all adverse rulings below are void, the Court may—
6 consistent with Texas law—grant Appellant’s requested relief without awaiting
reassignment to a new trial judge. Appellant respectfully requests that the Court:
1. IMPOSE SANCTIONS under TRAP 45, CPRC § 10.001, and inherent
authority;
2. Award Appellant her judgment, fees (if any), and just damages;
3. Issue any further relief necessary to deter similar conduct.
VII. PRAYER
WHEREFORE, Appellant respectfully prays that this Court strike GLO’s
frivolous Motion to Dismiss, impose appropriate sanctions, and grant all further
relief to which Appellant is entitled.
Date: November 25, 2025
/s/ Cedric M. Scott
Cedric M. Scott, PhD Appellant, Pro Se 901 Hidden Valley Drive, #9204 Round Rock, Texas 78665 Email: cedricscott41@gmail.com
7 CERTIFICATE OF SERVICE
Pursuant to Texas Rule of Appellate Procedure 9.5, I hereby certify that on
this 25th day of November 2025, a true and correct copy of the foregoing Motion
for Sanctions Against GLO Filing a Frivolous Motion to Dismiss was e-filed and
served via electronic service (e-service) to the Court and:
Counsel for the General Land Office
Sara Labashosky State Bar No. 24129467 slabashosky@bickerstaff.com
Gunnar P. Seaquist State Bar No. 24043358 gseaquist@bickerstaff.com
Bickerstaff Heath Delgado Acosta LLP 3711 S. MoPac Expressway Building One, Suite 300 Austin, Texas 78746 (512) 472-8021
/s/ Cedric M. Scott Cedric M. Scott, PhD Appellant, Pro Se
8 PROPOSED ORDER
CAUSE NO.: 15-25-00217-CV (Transferred from the Third Court of Appeals)
IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS
CEDRIC M. SCOTT, PhD, Appellant, Pro Se
GENERAL LAND OFFICE OF THE STATE OF TEXAS, Appellee
On Appeal from the 250th Judicial District Court Travis County, Texas Trial Court Cause No. D-1-GN-25-000006
PROPOSED ORDER APPELLANT’S MOTION FOR SANCTIONS AGAINST GLO FOR FILING A FRIVOLOUS MOTION TO DISMISS
On this day, the Court considered Appellant’s Motion for Sanctions Against
GLO for Filing a Frivolous Motion to Dismiss. After reviewing the motion, the
Court’s file, and applicable law, the Court finds that the Motion is well-taken and
should be GRANTED. IT IS THEREFORE ORDERED that:
1. The General Land Office’s Motion to Dismiss is STRICKEN as frivolous
and legally improper;
2. The General Land Office is hereby SANCTIONED pursuant to Tex. R.
App. P. 45, Tex. Civ. Prac. & Rem. Code § 10.001 et seq., and the Court’s
inherent authority;
9 3. The Court awards just damages and costs in an amount to be determined.
IT IS SO ORDERED.
SIGNED this ____ day of ______________________, 2025.
________________________________ Justice, Fifteenth Court of Appeals
10 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.
Envelope ID: 108469030 Filing Code Description: Motion - Exempt Filing Description: Motion To Strike Status as of 11/25/2025 4:38 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Jeffrey Moore jmoore@bickerstaff.com 11/25/2025 3:53:47 PM SENT
Gunnar Seaquist gseaquist@bickerstaff.com 11/25/2025 3:53:47 PM SENT
Sara Labashosky slabashosky@bickerstaff.com 11/25/2025 3:53:47 PM SENT
Cedric M.Scott cedricscott41@gmail.com 11/25/2025 3:53:47 PM SENT