Cedric M. Scott, PhD v. General Land Office of the State of Texas

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.

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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.
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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.
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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
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• 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—

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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

Respectfully submitted,

/s/ Cedric M. Scott

Cedric M. Scott, PhD
Appellant, Pro Se
901 Hidden Valley Drive, #9204
Round Rock, Texas 78665
Email: cedricscott41@gmail.com

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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

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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

v.

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;

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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

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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