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Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 25, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · Lackawanna CCCP, USA · 2026-09-25

Coyne v. Smurl

What happened

In Lackawanna CCCP, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • False Quotes (Case Law)
    The plaintiffs cited “Babac v. Pennsylvania Milk Marketing Board, Supreme Court of Pennsylvania 1990” and attributed to it the statement that the Sunshine Act imposes obligations directly upon the agency and its members. The court found no such quotation in Babac or any reported Pennsylvania federal or state case.
  • Misrepresented (Case Law)
    The plaintiffs cited “Ackerman v. Upper Mt. Bethel Township, Commonwealth Court, 2015” and claimed it held that the Sunshine Act applies to the agency and each participating member. The court found no such 2015 decision, identified the actual case as Ackerman v. Upper Mt. Bethel Township, 567 A.2d 1116 (Pa. Cmwlth. 1989), and stated that it did not contain the quoted proposition.
  • False Quotes (Case Law)
    The plaintiffs cited “Reading Eagle Company v. Council of the City of Reading, Commonwealth Court, 1999” and claimed it held that members participating in an illegal meeting may be subject to penalties under Section 714. The court corrected the citation to Reading Eagle Co. v. Council of City of Reading, 627 A.2d 305 (Pa. Cmwlth. 1993), which addressed specificity of executive-session reasons and did not contain the quoted holding.
  • False Quotes (Case Law)
    The plaintiffs cited “Smith v. Township of Richmond, Commonwealth Court, 2003” and attributed to it the statement that the Sunshine Act authorizes penalties against public officials who knowingly participate in illegal meetings. The court identified the actual Commonwealth Court decision as Smith v. Township of Richmond, 54 A.3d 404 (Pa. Cmwlth. 2012), affirmed at 82 A.3d 407 (Pa. 2013), and stated that neither court issued the quoted holding.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Not specified in source record.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/3183/Coyne_v._Smurl_USA_25-09-2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).