Courts on AI / Fabricated or misquoted citations

A.C. Appellant v. H.D. AND J.C.

Superior Court of Pennsylvania · State appellate courts · PA · 2026-03-13 · 2026 WL 711256 · No. No. 2364 EDA 2025 · opinion

Fabricated or misquoted citations

Superior Court of Pennsylvania on 2026-03-13 in A.C. Appellant v. H.D. AND J.C. found the self-represented party's appellate brief contained three citation defects, including Commonwealth v. Lyons, involving nonexistent authorities, mischaracterized authority. The court affirmed the order dismissing the custody petition with prejudice and did not rely on the defective authorities.

Disposition: The court affirmed the order dismissing the custody petition with prejudice and did not rely on the defective authorities.
Recorded conduct: The self-represented party's appellate brief contained three citation defects, including Commonwealth v. Lyons, involving nonexistent authorities, mischaracterized authority. — 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.

day deadline; the current version, effective since October 1, 2020, does not. Compare Pa.R.C.P. 1915.5(a) (current version), with Pa.R.C.P. 1915.5(a) (prior version effective until Sept. 30, 2020). 6 Based upon our review of Stepmother's brief and the cases cited therein, we suspect she used generative artificial intelligence in drafting it. See Saber v. Navy Federal Credit Union, 2026 WL 194332, at *3 n.4 (Pa. Super. Jan. 14, 2026) (discussing generative artificial intelligence “hallucinations,” wherein program makes up cases that do not exist). While we may liberally construe materials filed by pro se litigants, they are still subject to the same rules as represented litigants. See Commonwealth v. Blakeney, 108 A.3d 739, 766 (Pa 2014). Therefore, all litigants using generative artificial intelligence must ensure that the citations in their briefs are to real cases, or they risk waiving them for failure to cite to “pertinent” authority. See Pa.R.A.P. 2119(a). 7 While we found three Pennsylvania cases decided in 2003 with the caption Commonwealth v. Lyons, none stand for the proposition Stepmother cites it for or appear at the reporter citation she provides.

Authorities cited in the passage: Brief cites a reported Commonwealth v. Lyons at a reporter citation and for a proposition the court found unsupported · See Saber v. Navy Federal Credit Union, 2026 WL 194332 · See Commonwealth v. Blakeney · While we found three Pennsylvania cases decided in 2003 with the caption Commonwealth v. Lyons

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: official copy pending

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