Monday, October 19, 2026

Court Addresses AI Hallucinations in Filings By Pro Se Litigant


In the case of Coyne v. Smurl, No. 2025-CV-5844 (C.P. Lacka. Co. Sept. 25, 2026 Nealon, J.), the court issued a decision addressing Preliminary Objections filed in a matter involving the Sunshine Act.

Of note, on pgs. 8-10, and in footnote 4 of the Opinion, Judge Terrence R. Nealon of the Lackawanna County Court of Common Pleas points out that the pro se litigant in this case appeared to have relied upon generative artificial intelligence (“GenAI”) in creating its filings given that a number of the citations offered up to the court by the pro se litigant were not accurate.

The court noted that, under Pa. R.C.P. 1023.1(c)(2), as well as the local rules of court in Lackawanna County, the signature of an attorney or a self-representative party on a court filing constitutes a certification by that attorney or party that the claims, defenses, and other legal contentions set forth in the filing “are warranted by existing law or by a nonfrivolous argument for the extension, modification or reversal of existing law, or the establishment of new law.”

As such, the court noted that attorneys and pro se litigants have a duty to independently verify the accuracy of all citations generated by AI and the legitimacy of the holdings and the rationales that AI attributes to those identified cases before submitting any filings of record.


Anyone wishing to review a copy of this decision may click this LINK.

Source of image: Photo by Igor Omilaev on www.unsplash.com.


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