Spanish court rules researcher plagiarized colleague, orders withdrawal of works  

Spain’s Supreme Court in Madrid
Cberbell/Wikimedia Commons

The Supreme Court of Spain has ordered a literary scholar to pursue retractions of nine works it determined were plagiarized.     

The Tribunal Supremo upheld a lower court’s ruling that narrative theory researcher Franciscó Álamo Felices, a professor at the University of Almería in Spain, plagiarized a colleague’s work in two books and seven articles. José R. Valles Calatrava, a literary theory professor at the same university, sued Felices in 2019 for infringement of his intellectual property rights.

That lower court found Felices responsible for “a huge amount of plagiarism at different times and in different articles, revealing a systematic and conscientious parasitic attitude and a desire for appropriation,” according to a translation of the ruling by DeepL Translate. In an October 2025 decision, the Tribunal Supremo dismissed an appeal by Felices against the ruling, finding he failed to demonstrate any fundamental errors of law. 

Felices is obligated to withdraw the two books and seven articles or to “clearly mark them as plagiarism,” according to the judgment.    

Felices told us he did not plagiarize the works, and that the pieces simply expanded upon entries in a book he cowrote with Calatrava: Diccionario de Teoría de la Narrativa. The dictionary contains nearly 1,000 terms in various fields of narratology, Felices said. 

In addition, the university dismissed a complaint about this issue, he told us in Spanish, finding no plagiarism occurred. 

“However, the judge interpreted it from a different legal perspective, which we must respect,” he said. 

Felices has had work retracted in the past for duplication of his own prior work.

In his complaint, Calatrava accused Felices of writing nine texts plagiarizing work in three of Calatrava’s books. 

Calatrava’s books were published between 1990 and 1999, and Felices’ two books and seven articles were published between 2009 and 2017. 

In addition to Diccionario de Teoría de la Narrativa published in 2002, the two professors cowrote Fundamentos de la semiótica narrativa, published in 2000. 

Calatrava learned about the plagiarism through a Google reference to one of his quotes when he returned to the university in mid-2017 after traveling, he told us. The first article Calatrava came across was “only the tip of the iceberg of a whole series of plagiarism,” he said. 

Felices plagiarized Calatrava’s work in two books, the court ruled — La literatura y su estudio: Teorías literarias and Principios teóricos y metodológicos de teoría de la narrativa . The court also deemed literary research articles in seven different journals plagiarism. 

Felices denied appropriating Calatrava’s works, arguing more than half of the texts consisted of direct quotations, and that a substantial part of the publications “contained abundant indirect references made in accordance with the standard procedures in the citation and bibliography,” according to a translation of his defense in court documents. Felices’ texts also consisted of “a modest portion of vocabulary used in the discipline and employed in all works related to the subject, which excludes the possibility of plagiarism,” he argued. He also contended the alleged plagiarism came from his collaborative works with Calatrava. 

Court records indicate the University of Almería dismissed a complaint filed with the university with the same allegations. Judges noted, however, the university determined “the facts — whether true or not — did not constitute a disciplinary offense of any kind, without ruling out the existence of plagiarism at any time,” according to a translation of court documents. 

An initial lower court ruled in favor of Calatrava, and Felices appealed. After reviewing the texts, appeals judges found striking similarities, concluding with “overwhelming certainty” that Felices’ texts were written with Calatrava’s in mind, with “a clear parasitic intent, changing only the least relevant terms in terms of their significance, maintaining even the arrangement and rhythm of the sentences and, of course, the original scientific or discipline-specific terms,” according to a translation of the appeals court decision. 

“It should also be borne in mind that in the particular case of copying/plagiarism without attribution, the figure of the author is being erased, and it is no longer a question of violating the integrity of the work or infringing purely economic rights, but rather of breaking the link between the author and his work in order to simply appropriate the result of the author’s creative activity,” a translation of the appeals ruling states. “Thus, the infringement of removing the author and stealing their work is the most serious form of infringement of moral rights, as it amounts to depriving them of their authorship.”

The appeals court added because both Felices and Calatrava belong to the same university department, the impact to Calatrava is greater due to the academic relevance, “the commotion it has undoubtedly caused, and the considerable impact on coexistence and the working environment within the workplace,” according to a translation of the ruling. 

The Tribunal Supremo threw out Felices’ second appeal. In addition to withdrawing the works, Felices was ordered to pay Calatrava 5,000 euros for moral damages caused.

Calatrava was pleased with the legal outcome, he said. While his reputation and research career have not been affected, the ordeal has created psychological distress and caused him to take time off work, he told us. 

“In my opinion, victims of plagiarism are poorly understood and even less supported,” he said. “But believe me, the ultimate triumph of justice, albeit belated, puts everyone in their place and soothes the wound.”

At least four texts have since been withdrawn, including articles in Decenda, Cronopio, Anuario de Estudios Filológicos, and Tropelías.


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