What was hallucinated

Misrepresented: Case Law | Counsel quoted Kiessling v. State Farm, citing language said to be from Santiago v. Warminster Twp.; court found the quoted language does not exist in Santiago and the attribution/misquote is inaccurate. || Misrepresented: Case Law | Incorrect reporter volume number for a Third Circuit unpublished opinion: counsel cited '56 F. App'x 133' instead of the correct '506 F. App'x 133' for Smith v. State Farm Auto. Ins. Co. || Misrepresented: Case Law | Incorrect pincite and mixed database locators for Jones v. Allstate: counsel cited '2017 U.S. Dist. LEXIS 93673, at *2-3' and then 'Id. at *2-3' though the quoted language appears at *5 in the LEXIS entry and at *2-3 in the 2017 WL entry; miscitation noted. || Misrepresented: Case Law | Repeated omission of pincites/electronic report numbers and reproduction of language without quotation marks for cases (e.g., Zaloga, Hoffer, Stepanovich, Schwendinger-Roy, Wagner); court flagged these as inaccurate citation practices. || Misrepresented: Case Law | Apparent copying of miscitations and inaccurate quotations from prior filings in other matters (similar miscitations found in earlier Liberty Mutual filings in Tsirikis-Brown, Blazejewski, Giraldo); court noted potential copying across briefs.

Sanction teardown · E.D. Pennsylvania, USA · 2026-02-13

Nydia Rosario v. Liberty Mutual Personal Insurance Company

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)

Counsel quoted Kiessling v. State Farm, citing language said to be from Santiago v. Warminster Twp.; court found the quoted language does not exist in Santiago and the attribution/misquote is inaccurate.
Misrepresented (Case Law)

Incorrect reporter volume number for a Third Circuit unpublished opinion: counsel cited '56 F. App'x 133' instead of the correct '506 F. App'x 133' for Smith v. State Farm Auto. Ins. Co.
Misrepresented (Case Law)

Incorrect pincite and mixed database locators for Jones v. Allstate: counsel cited '2017 U.S. Dist. LEXIS 93673, at *2-3' and then 'Id. at *2-3' though the quoted language appears at *5 in the LEXIS entry and at *2-3 in the 2017 WL entry; miscitation noted.
Misrepresented (Case Law)

Repeated omission of pincites/electronic report numbers and reproduction of language without quotation marks for cases (e.g., Zaloga, Hoffer, Stepanovich, Schwendinger-Roy, Wagner); court flagged these as inaccurate citation practices.
Misrepresented (Case Law)

Apparent copying of miscitations and inaccurate quotations from prior filings in other matters (similar miscitations found in earlier Liberty Mutual filings in Tsirikis-Brown, Blazejewski, Giraldo); court noted potential copying across briefs.

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

Obligation to share decision with firm

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/1531/NYDIA_ROSARIO_v_LIBERTY_MUTUAL_PERSONAL_INSURANCE_COMPANY.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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