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Courts on AI / Fabricated or misquoted citations

Jaclyn Cocco v. Rosario Palmieri, Jr.

Supreme Court of Pennsylvania · State supreme courts · PA · · 2026 WL 1506862 · No. 2429 EDA 2025 · order

On 2026-05-29, in Jaclyn Cocco v. Rosario Palmieri, Jr, Supreme Court of Pennsylvania affirmed and observed that an asserted parental-alienation authority could not be located. A self-represented appellant filed a petition using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

Disposition
The court affirmed and observed that an asserted parental-alienation authority could not be located.
Recorded conduct
A self-represented appellant filed a petition using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support. — outcome: other; actor: litigant in person
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.

To the extent Father contends that this court has mandated dispositiveweightbeattributedtofactorsconcerningparental alienationasamatteroflaw,heisincorrect.Indeed,itappears that the authority to which Father cites in support of this contention either does not exist or does not stand for the proposition for which he asserts it does. Notably, Father's brief includes the following quotation: “Where the record demonstrates that one parent has engaged in a sustained campaign to alienate the children from the other parent, ... [t]he court must act to protect the best interests of Children and cannot permit a parent to benefit from such misconduct. [sic] E.D., 33 A.3d at 83 [sic]. Appellant's Brief at 39-40 (emphasis present in original, ending quotation marks missing in original). This Court can find no such case using the citation provided by Father, nor any other source for the quoted language. Rather, the citation provided directs this Court to Discover Bank v. Stucka, 33 A.3d 82 (Pa. Super. 2011), an opinion entirely unrelated to child custody and containing no discussion of parental alienation. Additionally, Father cites to this Court's opinion in S.M. v. J.M., 811 A.2d 621, 625 (Pa. Super. ... Shortly thereafter, on June 6, 2025, Father filed an additional petition for contempt, and a hearing was scheduled for June 12, 2025. At the outset of that hearing, the lower court, with the assistance of counsel, assembled a list of petitions which had at that time not yet been ruled upon. During that hearing, the lower court proposed consolidation of the outstanding petitions as each addressed “the same nucleus of activity,” and no party objected. Notes of Testimony 6/12/2025 at 6-10. Following testimony regarding mother's alleged contempt, the lower court noted that it would continue to hold the pending petitions in abeyance. Id.

Authorities cited in the passage: Court to Discover Bank v. Stucka, 33 A · Father cites to this Court's opinion in S.M. v. J.M., 811 A

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