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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

United States Judicial Panel on Multidistrict Litigation · Federal specialty courts · · No. MDL No. 3014 · order

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 Gravelyn action to the Western District of Pennsylvania and admonished plaintiff and counsel for false legal representations.
Recorded conduct
Plaintiff’s brief cited two Panel decisions; one reporter citation pointed to a different MDL and neither Xarelto nor Eliquis supported the individualized-circumstances proposition asserted. — 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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