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Courts on AI / Fabricated or misquoted citations

Nydia Rosario v. Liberty Mutual Personal Insurance Company

United States District Court for the Eastern District of Pennsylvania · Federal district courts · PA · · 2026 WL 413438 · No. CIVIL ACTION NO. 26-276 · order

Eastern District of Pennsylvania on 2026-02-13 in Nydia Rosario v. Liberty Mutual Personal Insurance Company found counsel's brief contained five citation defects, including Id. at *2-3, Kiessling v. State Farm and Santiago v. Warminster Twp, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to share the decision with the firm and address the citation-verification failure internally.

Disposition
The court ordered counsel to share the decision with the firm and address the citation-verification failure internally.
Recorded conduct
Counsel's brief contained five citation defects, including Id. at *2-3, Kiessling v. State Farm and Santiago v. Warminster Twp, involving nonexistent authorities, fabricated or misattributed quotations. — outcome: other; 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.

‘all reasonable inferences that can be drawn from’ those allegations ... and, construing the allegations and reasonable inferences ‘in the light most favorable to the [plaintiff]’..., we determine whether they ‘plausibly give rise to an entitlement to relief.’ ” Oakwood Lab'ys LLC v. Thanoo, 999 F.3d 892, 904 (3d Cir. 2021) (internal citations omitted). 15 ECF 15-1 at 5–8. 16 Trial counsel and judges increasingly work under a risk of miscitations or unsupported arguments patched from artificial intelligence favored by many lawyers. We have no reason to today find the abuse of artificial intelligence research. We instead see old-fashioned lack of diligence. Counsel is professionally obligated (compounded by risk to their and their law firm's reputations) to be diligent in ensuring the accuracy of citations and quotations in briefing submitted to us and our colleagues. Experienced federal lawyers know our talented lawyers in Chambers study their work product to advise the judges. And these Chambers's lawyers are unfairly burdened in a busy urban federal court docket. We rely on counsel to present accurate citations.

Authorities cited in the passage: 56 F. App · instead of the correct · x 133 · 2017 U.S. Dist. LEXIS 93673, at *2-3 · Id. at *2-3 · Counsel quoted Kiessling v. State Farm · Santiago v. Warminster Twp · F. App'x 133' instead of the correct '506 F. App'x 133' for Smith v. State Farm Auto. Ins. Co · Incorrect pincite and mixed database locators for Jones v. Allstate · Oakwood Lab'ys LLC v. Thanoo

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