Pennsylvania — AI Regulations

16 MAR 2026 · Court Case

Domingo Beato-Estrella v. M. Arviza

Fabricated: Case Law | Petitioner cited 'Santos v. Warden Allenwood FCI, No. 1:17-CV-02116, 2018 WL 1178251 (M.D. Pa. Mar. 6, 2018)'; court found no such M.D. Pa. decision — the 2018 WL number corresponds to Certain Underwriters at Lloyd's, London v. Pettit (W.D. Wash.), unrelated to petitioner's claim. || Fabricated: Case Law | Petitioner cited 'Rodriguez v. Ebbert, No. 3:14-CV-02404, 2015 WL 1810315 (M.D. Pa. Apr. 21, 2015)'; court found 2015 WL 1810315 corresponds to an unrelated Florida appellate decision (D.S. v. Dep't of Child. & Fams.), not the cited M.D. Pa. case. || Fabricated: Case Law | Petitioner cited 'Cruz v. United States, No. 1:16-CV-01034, 2016 WL 8732312 (M.D. Pa. Dec. 16, 2016)'; court found 2016 WL 8732312 corresponds to Black Water Mgmt., LLC v. Sprenkle (E.D. Va.), not the cited M.D. Pa. decision. || Misrepresented: Case Law | When using this court's docket numbers, petitioner identified cases (e.g., Firestone v. Rockovich, No. 1:17-CV-2116; Fagal v. Marywood Univ.; Drake v. Warden of Allenwood Low) that exist but are irrelevant to his claim — the court treated these as misattributed and not supportive of petitioner's position.

Court: M.D. PennsylvaniaParty: Pro Se Litigant

Harms: Hallucination in legal filings

13 MAR 2026 · Court Case

A.C. Appellant v. H.D. AND J.C.

Fabricated: Case Law | Brief cites a non-existent case, which the court determined does not exist and was likely generated by AI. || Misrepresented: Case Law | Brief cites a reported Commonwealth v. Lyons at a reporter citation and for a proposition the court found unsupported; court found no case at that citation supporting appellant's use. || Misrepresented: Case Law | Brief cites In re Ullman but attributes a proposition to it that the case does not stand for; court found the citation exists but was misused.

Court: SC PennsylvaniaParty: Pro Se Litigant

Harms: Hallucination in legal filings

13 FEB 2026 · Court Case

Nydia Rosario v. Liberty Mutual Personal Insurance Company

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 || Misrepresented: Case Law | Incorrect reporter volume number for a Third Circuit unpublished opinion: counsel cited '56 F. App'x 133' instead of the correct '506 F. App'x 133' for Smith v. State Farm Auto.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

Court: E.D. PennsylvaniaParty: Lawyer

Harms: Hallucination in legal filings

02 FEB 2026 · Court Case

Emmanuel S. Yirenkyi v. Angela Hoover

Fabricated: Case Law | Petitioner cited 'Frederick v. Warden, 2019 WL 1318445 (M.D. Pa. Mar. 22, 2019)' to support that 8–10 months detention requires release; court found no such Middle District of Pennsylvania decision and labeled it an AI-generated legal hallucination. || Fabricated: Case Law | Petitioner cited 'Rodriquez v. Lowe, 2018 WL 683974 (M.D. Pa. Feb. 2, 2018)'; the court found the provided Westlaw citation redirected to an unrelated Quebec family-court decision and concluded no such M.D. Pa. case exists, calling it a legal hallucination.

Court: M.D. PennsylvaniaParty: Pro Se LitigantTool: Unidentified

Harms: Hallucination in legal filings

26 JAN 2026 · Court Case

Lifetime Well LLC v. IBSpot.com Inc.

False Quotes: Case Law | Motion included an alleged quotation that does not appear in the cited opinion; opposing counsel flagged the nonexistent quote from a Pennsylvania case. || Fabricated: Case Law | Multiple AI-generated, non-existent case opinions were cited in the Motion; Court identified eight defective citations. || Misrepresented: Case Law | Several real cases were cited but did not support the propositions asserted or were from inapposite jurisdictions (mischaracterized holdings).

Court: E.D. PennsylvaniaParty: LawyerTool: Lexis+ AI; LexisNexis Protégé

Fine: 4000

Harms: Hallucination in legal filings

14 JAN 2026 · Court Case

Saber v. Navy Federal Credit Union

Fabricated: Case Law | Appellant cited 'D'Happart v. First Commonwealth Bank' with two reporter citations; the court found no such cases exist at those citations and said the authority did not support Appellant's argument. || Fabricated: Case Law | Appellant's brief contained several other case citations that 'do not exist'; Appellee suggested the errors resulted from use of generative AI and the court noted multiple counterfeit authorities in the brief.

Court: SC PennsylvaniaParty: Pro Se Litigant

Harms: Hallucination in legal filings

01 JAN 2026 · Law / Act

2026 Chatbot Legislation — Pennsylvania SB 1090 [URL: https://www.palegis.us/legislation/bills/2025/sb1090]

2026 chatbot legislation — Passed Chamber

Generative AI ·Data Privacy & Protectionpalegis.us ↗

17 DEC 2025 · Court Case

Russel Williams Home Services LLC v. Minleon International (USA) Limited LLC, et al.

False Quotes: Case Law | Minleon attributed a quotation to Abbott Lab'ys v. Sandoz, Inc. that does not appear in that case; the court found the purported quote invented and noted Sandoz actually says price erosion is evidence of irreparable harm. || False Quotes: Case Law | Minleon attributed a quotation to Abbott Lab'ys v. Andrx Pharms., Inc. that does not appear in that case; the court found no federal case contained the quoted language and labeled the brief's behavior unacceptable.

Court: M.D. PennsylvaniaParty: Lawyer

Harms: Hallucination in legal filings

15 DEC 2025 · Court Case

Robert W. Williams, Sr. v. Assistant District Attorney John R. Canavan, et al.

Misrepresented: Case Law | AI misrepresented the jurisdiction and precedential weight of Doe v. Public Citizen, claiming it was a Third Circuit on-point decision when it is a Fourth Circuit case about access to judicial records. || False Quotes: Case Law | AI-aided motion cited Doe v. Public Citizen for a proposition about guardian ad litem appointment that the opinion does not contain; court found the quoted page/analysis unrelated.

Court: M.D. PennsylvaniaParty: Pro Se LitigantTool: Unidentified

Harms: Hallucination in legal filings

05 DEC 2025 · Court Case

Mullins v. Duquesne University of the Holy Spirit

False Quotes: Case Law | Plaintiff attributed a quote to Long v. SEPTA that does not appear in the Long opinion; court treated this as a phantom/erroneous quote identified by defense counsel. || False Quotes: Case Law | Plaintiff quoted Burlington Coat Factory as stating the futility standard is 'identical' to the Rule 12(b)(6) standard, whereas the Third Circuit used 'the same' — an inaccurate quotation. || False Quotes: Case Law | Plaintiff inserted brackets in the Supreme Court quote 'freely give[n]' from Foman v. Davis though the brackets/alteration do not appear in the original quotation.

Court: W.D. PennsylvaniaParty: Pro Se Litigant

Harms: Hallucination in legal filings

03 DEC 2025 · Court Case

United States v. Brian Boehm

Misrepresented: Case Law | Cited United States v. Helena, 906 F.3d 288, 291 (3d Cir. 2018) to suggest only a court (not probation) may impose supervised-release conditions; Helena did not involve a probation officer imposing conditions and was mischaracterized. || False Quotes: Case Law | Quoted Albertson as stating probation officers 'lack authority' to expand judicial conditions; the phrase does not appear in the published opinion and the case was misapplied. || False Quotes: Case Law | Attributed statements to United States v. Miller, 594 F.3d 172 (3d Cir. 2010) about explicit imposition of monitoring costs; the court found those quotes and propositions false and Miller was misused.

Court: M.D. PennsylvaniaParty: Pro Se Litigant

Harms: Hallucination in legal filings

22 OCT 2025 · Court Case

John Weaver v. Shasta Services

Fabricated: Case Law | One case citation in Plaintiff's original Brief in Opposition was identified by the Court as an AI-generated fabricated case citation; Plaintiff later refiled acknowledging the citation was defective. || Fabricated: Case Law | A second case citation in Plaintiff's original Brief in Opposition was identified by the Court as an AI-generated fabricated case citation; Plaintiff refiled with an exhibit noting the citation did not adequately address the issues.

Court: W.D. PennsylvaniaParty: Pro Se Litigant

Harms: Hallucination in legal filings

28 AUG 2025 · Court Case

Lonnie Allbaugh v. University of Scranton

Fabricated: Case Law | Quoted language allegedly from the cited case—"We do not require a plaintiff to plead a prima facie case of discrimination to survive a motion to dismiss."—which does not appear in the actual case plaintiff said he meant || Fabricated: Case Law | Submitted a non-existent Third Circuit case as authority; opposing party and court could not locate the opinion and plaintiff later admitted the citation was AI-generated.

Court: M.D. PennsylvaniaParty: Pro Se LitigantTool: Unidentified

Fine: 1000 USD

Harms: Hallucination in legal filings

22 JUL 2025 · Court Case

Victor Kholod v. Nationstar Mortgage LLC

Fabricated: Case Law | According to Kholod, “PA Partnership Inc. v. XYZ Corp, 2020” “involved the wrongful withdrawal of funds from one company's account by another, resulting in compensation to the aggrieved party.” Doc 1-2 at 4. We have been unable to locate any possible case that might fit the description given for this case. Defendant Wells 5Fargo's brief in support stated that its search for this case was fruitless as well. Doc. 5 at 20. || Misrepresented: Case Law | 2. Per Kholod, in “Levy Baldante Finney & Rubenstein v. Wells Fargo Bank, 2018” “[t]he court held the company liable for failing to prevent unauthorized transactions.”Doc. 1-2 at 4. In its brief, Defendant Wells Fargo Bank points the court to Levy Baldante Finney & Rubenstein, P.C. v. Wells Fargo Bank, N.A., No. 3241 EDA 2016, 2018 WL 847756 (Pa. Super. Ct. Feb. 14, 2018). Doc. 5 at 20-21. This case, however, involved fraudulent endorsements on checks that had been withdrawn from a law firm's IOLTA accounts and business accounts. Levy Baldante Finney & Rubenstein, P.C., 2018 WL 847756, at *3. Neither the facts nor the legal analysis in this case supports Kholod's claim for relief. We were unable to find another case that fit the citation provided by Kholod. || Fabricated: Case Law | 3. Kholod also cites “Chasen v. Littman, 2019” in which, according to Kholod, “[t]he court considered the issue of unauthorized use of funds between companies.”Doc. 1-2 at 4. In its brief, Defendant Wells Fargo Bank provides the following as the proper citation for this case: L. Offs. of Bruce J. Chasan, LLC v. Pierce Bainbridge Beck Price & Hecht, LLP, No. 2:18CV-05399-AB, 2019 WL 1957950 (E.D. Pa. May 2, 2019), aff'd, 792 F. App'x 195 (3d Cir. 2019). Doc. 5 at 21. This case does not support Kholod's claim for relief; it involved an attorney's attempt to recover a contingency fee from an out of state attorney. L. Offs. of Bruce J. Chasan, LLC, 2019 WL 1957950 at *1–2. We were unable to find another case that fit the ci

Court: M.D. PennsylvaniaParty: Pro Se Litigant

Harms: Hallucination in legal filings

20 SEP 2023 · Executive Order

Pennsylvania Executive Order 2023-19

Establishes the Generative AI Governing Board to oversee AI use, ensuring alignment with core values such as accuracy, equity, and privacy. Instructs the Office of Administration to develop policies and training for responsible AI use within Pennsylvania's agencies.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2pa.gov ↗

29 JUN 2023 · Other

Pennsylvania HR 170

Directs the Joint State Government Commission to study AI's impact in Pennsylvania, establish an advisory committee, and assess AI development, risks, and benefits. Requires legislative proposals, ethical guidelines, and an evaluation report within 18 months to state leaders.

Financial Services ·Education ·Health & Life Sciences ·+11legiscan.com ↗

12 JUN 2023 · Other

Pennsylvania HB 1380

Utilizes artificial intelligence for eligibility verification and fraud detection in public assistance programs. Authorizes data access from state agencies to verify residency and eligibility. Prioritizes job training programs to increase employment and self-reliance.

Financial Services ·Education ·Health & Life Sciences ·+2legis.state.pa.us ↗

28 APR 2023 · Law / Act

An Act amending Title 18 (Crimes and Offenses) of the Pennsylvania Consolidated Statutes, in sexual offenses, providing for the offense of unlawful dissemination of artificially generated depiction; and, in minors, further providing for the offense of sexual abuse of children and for the offense of transmission of sexually explicit images by minor.

Makes it illegal to disseminate deepfake pornography -- lifelike visual content that depicts sexual scenes which did not occur in reality, including images of nudity and sexual acts -- in the state of Pennsylvania.

Financial Services ·Education ·Health & Life Sciences ·+6legis.state.pa.us ↗

07 MAR 2023 · Other

Pennsylvania HB 49

Establishes a registry for businesses operating AI systems in Pennsylvania. Requires submission of business details, including code type and contact information. Prohibits commercial use of collected data. Mandates annual reporting to legislative committees. Defines "artificial intelligence."

Financial Services ·Education ·Health & Life Sciences ·+6legis.state.pa.us ↗