Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 9, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · E.D. Pennsylvania, USA · 2026-09-09

Pennmark Coventry Holdings, LLC v. Kohl’s Department Stores, Inc.

What happened

In E.D. Pennsylvania, 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:

Misrepresented (Case Law)

Plaintiff attributed to Kannankeril the proposition that the classic Daubert factors are not applicable to experience-based testimony. The Court found no such quoted language and explained that Kannankeril instead held that the factors are non-exhaustive and may not apply in every case, while still requiring analysis of reliability, sources, and methods.
Misrepresented (Case Law)

Plaintiff attributed to Kumho Tire the proposition that reliability for experience-based testimony depends heavily on the expert’s knowledge and experience rather than methodology or theory. The Court could not locate the quoted language and explained that Kumho held that Daubert’s general principles apply to all Rule 702 expert matters, including experience-based testimony, and that some Daubert questions may be useful in evaluating it.

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/3130/PENNMARK_COVENTRY_HOLDINGS_LLC_v._KOHLS_DEPARTMENT_STORES_INC._USA_9_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).