Jaclyn Cocco v. Rosario Palmieri, Jr.
SC Pennsylvania · May 29, 2026
What happened in this matter?
The Superior Court of Pennsylvania identified that the Appellant submitted fabricated case law and misrepresented existing authorities in his appellate brief. The court explicitly questioned whether these errors were the product of generative AI, though it did not impose a formal monetary or professional sanction, instead affirming the underlying custody order.
- Why the court cared
- The court reasoned that the Appellant's cited authority either did not exist or did not support the propositions asserted. It noted that the provided citations led to unrelated opinions, such as 'Discover Bank v. Stucka,' and explicitly stated that the court was left to guess whether the counterfeit authority was the product of a chatbot.
- Why it matters now
- This case illustrates judicial scrutiny of AI-generated hallucinations in appellate filings. It highlights the risk of 'counterfeit authority' and the court's willingness to explicitly flag potential AI misuse when counsel fails to verify the existence and accuracy of cited legal precedents.
Why this matter is tracked
In a child custody appeal, the Superior Court of Pennsylvania addressed the Appellant's reliance on fabricated and misrepresented legal authorities. The Appellant cited a non-existent case, 'E.D., 33 A.3d at 83,' to support a parental-alienation argument, which the court identified as a hallucinated citation. Additionally, the Appellant misrepresented 'S.M. v. J.M., 811 A.2d 621 (Pa. Super. 2002),' claiming it addressed parental alienation and 'irreparable harm,' when the opinion contained no such language or discussion. The court noted these errors, explicitly questioning whether the counterfeit authority resulted from the use of a generative AI chatbot. The court ultimately affirmed the trial court's custody order, finding no merit in the Appellant's arguments and noting the waiver of several procedural claims.
This case illustrates judicial scrutiny of AI-generated hallucinations in appellate filings. It highlights the risk of 'counterfeit authority' and the court's willingness to explicitly flag potential AI misuse when counsel fails to verify the existence and accuracy of cited legal precedents.
Record details
What the record establishes about AI use
The court questioned if the counterfeit authority was the product of a chatbot.
Appeal from a Final Custody Order entered by the Delaware County Court of Common Pleas; the Superior Court of Pennsylvania affirmed the trial court's decision.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Appellant quoted a parental-alienation passage and attributed it to a nonlocatable citation "E.D., 33 A.3d at 83 [sic]"; the court could find no such authority and determined the citation did not support the quoted language.
- Misrepresented: Case Law | Appellant cited S.M. v. J.M., 811 A.2d 621, 625 (Pa. Super. 2002) as supporting that failing to remedy alienation would 'irreparably harm' the child; the court found the cited opinion does not contain that language nor discuss parental alienation as claimed.
- Misrepresented: Case Law | Appellant's citation led to Discover Bank v. Stucka, 33 A.3d 82 (Pa. Super. 2011), an opinion unrelated to child custody, which Appellant had relied on for a parental-alienation proposition.
Questions this record answers
- What happened in Jaclyn Cocco v. Rosario Palmieri, Jr.?
- The Superior Court of Pennsylvania identified that the Appellant submitted fabricated case law and misrepresented existing authorities in his appellate brief. The court explicitly questioned whether these errors were the product of generative AI, though it did not impose a formal monetary or professional sanction, instead affirming the underlying custody order.
- Why does Jaclyn Cocco v. Rosario Palmieri, Jr. matter for legal AI risk?
- This case illustrates judicial scrutiny of AI-generated hallucinations in appellate filings. It highlights the risk of 'counterfeit authority' and the court's willingness to explicitly flag potential AI misuse when counsel fails to verify the existence and accuracy of cited legal precedents.
- What does the public record establish about Jaclyn Cocco v. Rosario Palmieri, Jr.?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Jaclyn Cocco v. Rosario Palmieri, Jr. summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.