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Courts on AI / Fabricated or misquoted citations

Kaspryak v. Stadarskyy

Superior Court of Pennsylvania · State appellate courts · PA · · 2026 PA Super 185 · No. 2781 EDA 2025 · opinion

The Superior Court of Pennsylvania affirms dismissal of Zoryana Kaspryak’s partition action. The court finds that two citations in her self-represented reply brief are hallucinated, explains that the reporter citations lead to different cases, and concludes her claims are waived for unsupported and fabricated authority.

Disposition
The court affirmed dismissal of the partition action and held the appellant waived claims through unsupported and fabricated authority.
Recorded conduct
Self-represented appellant cited General Fin. Co. v. Archetto and Lowrey v. Eastaff with reporter citations that led to different cases or a fabricated caption. — outcome: warning; 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.

Specifically, Appellant cites to “General Fin. Co. v. Archetto, 167 A.2d 306 (Pa. Super. 1961)” and “Lowrey v. Eastaff, 860 A.2d 533 (Pa. Super. 2004).” See id. (some formatting altered). These citations are so nonsensical and disconnected from Appellant’s claims that we conclude that they are hallucinated citations. To the extent that Appellant has employed generative artificial intelligence (“generative AI” or “GAI”) tools to draft her brief, as indicated by her repeated misrepresentations of the meaning of valid statutes and precedential opinions as well as her reliance on hallucinated authority, we note that the use of GAI to draft legal filings (including by pro se litigants), without verification of the accuracy of the content so produced, may lead to misstatements and/or misrepresentations of legal authority. ... We note that the Atlantic Reporter citation “167 A.2d 306” leads to a Pennsylvania Supreme Court opinion, Slott v. Plastic Fabricators, Inc., 167 A.2d 306 (Pa. 1961), not to a Pennsylvania Superior Court opinion captioned “General Fin. Co. v. Archetto” as Appellant states. ... In fact, “Lowrey v. Eastaff” appears to be an entirely fabricated caption, coupled with a hallucinated citation.

Authorities cited in the passage: General Fin. Co. v. Archetto, 167 A.2d 306 (Pa. Super. 1961) · Lowrey v. Eastaff, 860 A.2d 533 (Pa. Super. 2004) · Saber Healthcare Group, LLC v. Duchene, 350 A.3d 966 (Pa. Super. 2025) · Slott v. Plastic Fabricators, Inc., 167 A.2d 306 (Pa. 1961) · General Finance Corp. v. Archetto, 176 A.2d 73 (R.I. 1961) · Commonwealth v. duPont, 860 A.2d 525 (Pa. Super. 2004)

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