Another Pennsylvania Attorney Sanctioned by Court for Submitting Inaccurate Citations Apparently Secured From AI Resarch

In another Pennsylvania case involving an attorney utilizing AI hallucinations in a court filing, the court issued sanctions.

In Bevins v. Colgate-Palmolive Co., No. 25-576 (E.D. Pa. April 10, 2025 Baylson, J.), the attorney provided the court with case citations in court filings that were inaccurate and did not lead the reader to any identifiable court Opinion. The court noted that, based upon its search, it could not locate a case relative to the two citations at issue and/or could not detect a possible typographical error relative to the citation provided.

When the court ordered the attorney to provide an explanation, the attorney asserted that the inclusion of the incorrect citations was unintended given that he planned to replace the wrong cite with a proper one but failed to do so in his final draft. The court noted its concern as to why the attorney was silent as to his act of providing the court with case citations to decisions that did not exist and, as such, the court noted that it was “unconvinced by counsel’s explanations.”

The court referred to Rule 11 and sanctioned the attorney. The court also referred the matter to the State Bar.

Moreover, the court struck the attorney’s appearance in the case.  The attorney was ordered to advise the client of the sanctions and the fact that, should the Plaintiff chose to refile her case, she must find new counsel.

Anyone wishing to review the court's decision in Bevins may click this LINK.  The Court's companion Order can be viewed HERE.