Kiser v. DeSimone Auto Group

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

As Burton does not address either Pa.R.E. 404(B)(2) or res gestae, and as Appellants do not provide any discussion of ”Com v. Reid,” this Court’s review of Appellants’ argument to this point is substantially impaired. Further, in light of this unlocatable precedent, “this Court is left to guess whether this counterfeit authority is the product of a chatbot, or if there is a more nefarious explanation for the misinformation.” Commonwealth v. Shie, 307 A.3d 668, 2023 WL 6878610, at *7 n.7 (Pa. Super. 2023)(unpublished); see also Sanders v. United States, 176 Fed.Cl. 163, 169 (Fed. Cl. 2025)(observing "[i]t is no secret that generative AI programs are known to 'hallucinate' nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs" (internal citation omitted)).

Authorities cited in the passage: Pa.R.E. 404(B)(2) · Com v. Reid, 770 A.2d 771 (Pa. Super. 2001) · Commonwealth v. Burton, 770 A.2d 771 (Pa. Super. 1999) · Commonwealth v. Shie, 307 A.3d 668, 2023 WL 6878610 (Pa. Super. 2023) · Sanders v. United States, 176 Fed. Cl. 163 (Fed. Cl. 2025)