Courts on AI / Fabricated or misquoted citations

Twigg v. BSN Sports, Inc.

United States District Court for the Middle District of Pennsylvania · Federal district courts · PA · 2026-05-21 · No. 4:23-CV-00067 · memorandum opinion

Fabricated or misquoted citations Competence, fees and billing

On 2026-05-21, in Twigg v. BSN Sports, Inc., et al, the Middle District of Pennsylvania ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed a motion using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

Disposition: The court resolved post-trial motions and ordered plaintiffs’ counsel to show cause why he should not be sanctioned for Rule 11 violations involving AI and citations.
Recorded conduct: Plaintiffs’ counsel Nicholas Mattiacci filed a brief with fictitious cases, quotations absent from cited cases, and cases that did not support the asserted propositions, then characterized the problems as clerical errors. The court ordered a show-cause brief and hearing. — outcome: pending; 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.

The proliferation and availability of artificial intelligence (“AI”) tools and the ease with which litigants and attorneys can use them has caused an increase in citations to fictitious cases, quotations that do not appear in cases, and cases that do not support the propositions advanced.

Authorities cited in the passage: Rule 54.3 · Federal Rule of Civil Procedure 68.110

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document. Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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