Litigant Chided For Including AI Hallucinations in Appellate Filings

In the case of Saber v. Navy Federal Credit Union, No. 2449 EDA 2024 (Pa. Super. Jan. 14, 2026 Panella, P.J.E., Dubow, J., and Nichols, J.) (Op. by Nichols, J.), the Pennsylvania Superior Court again addressed an appeal in which a litigant (possibly pro se) utilized AI to draft the appellate submissions which submissions included citations to non-existent case law.

The case involved a dispute over a car loan.

In footnote 4 of its decision, the Pennsylvania Superior Court noted that the litigant provided “non-sensical citations to and characterization of" certain cases. The litigant’s Brief also contained citations to several other cases that did not exist. The court noted that these issues suggested that the litigant utilized generative artificial intelligence to draft his Brief.

The court noted that the party’s reliance upon these hallucinations led to a waiver of his claims on appeal. The Superior Court emphasized the importance of citing pertinent authority and pointed out the potential issues with using generative AI for legal filings without verifying the information secured.

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


Source: The Legal Intelligencer State Appellate Case Alert, www.Law.com (Feb. 3, 2026).

Source of image:  Photo by Ali Numan on www.unsplash.com.