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Courts on AI / Fabricated or misquoted citations

In re: Philips Recalled CPAP, Bi-Level PAP, and Mechanical Ventilator Products Liability Litigation (Gravelyn)

U.S. Judicial Panel on Multidistrict Litigation · Federal specialty courts · · No. MDL No. 3014 · order

Fabricated or misquoted citations

On 2026-04-06, U.S. Judicial Panel on Multidistrict Litigation the Panel transferred the listed action to MDL No. 3014 and warned that unverified AI-generated fictional citations undermine truthful court filings. Counsel submitted a filing with mischaracterized authorities, including In re Xarelto and In re Bard IVC Filters.

Disposition
The Panel transferred the listed action to MDL No. 3014 and warned that unverified AI-generated fictional citations undermine truthful court filings.
Recorded conduct
The filing used mischaracterized authorities, including In re Xarelto and In re Bard IVC Filters, which the court found nonexistent, misquoted, or unsupported. — outcome: warning; actor: lawyer
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

Nathaniel M. Gorton Matthew F. Kennelly Roger T. Benitez Dale A. Kimball Madeline Cox Arleo See Reilly v. Connecticut Interlocal Risk Mgmt. Agency, No. 3:25-00640, 2025 WL 1726366, at *2 (D. Conn. June 20, 2025) (“Artificial intelligence is known to result in . . . fictional or hallucinatory citations . . . . [B]ecause artificial intelligence synthesizes many sources with varying degrees of trustworthiness, reliance on artificial intelligence without independent verification renders litigants unable to represent to the Court that the information in their filings is truthful.”) (internal quotation marks and citation omitted). IN RE: PHILIPS RECALLED CPAP, BI-LEVEL PAP, AND MECHANICAL VENTILATOR PRODUCTS LIABILITY LITIGATION MDL No. 3014 SCHEDULE A Northern District of California GRAVELYN v. KONINKLIJKE PHILIPS N.V., ET AL., C.A. No. 3:25−10908

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