Nydia Rosario v. Liberty Mutual Personal Insurance Company
E.D. Pennsylvania · Feb 13, 2026
What happened in this matter?
The court directed defense counsel to share the memorandum with his law firm colleagues to ensure they are on notice regarding citation errors and to prevent future recurrence. No monetary or formal disciplinary sanctions were imposed.
- Why the court cared
- 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 || Misrepresented: Case Law | Incorrect reporter volume number for a Third Circuit unpublished opinion: counsel cited '56 F. App'x 133' instead of the correct '506 F. App'x 133' for Smith v. State Farm Auto.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.
- Why it matters now
- Copy-pasting citations across matters spreads hallucinations firm-wide; re-verify every carried-forward cite before filing.
Why this matter is tracked
In a breach of contract action, the court identified multiple citation errors in the defendant's briefing, including misquoted case law, incorrect reporter volume numbers, and missing pincites. The court noted that counsel appeared to have copy-pasted these inaccurate citations from prior filings in other matters. While the court declined to impose monetary or formal educational sanctions, it directed counsel to share the memorandum with his law firm colleagues to ensure future compliance with citation standards and to prevent the propagation of these errors. The court emphasized that counsel is professionally obligated to verify the accuracy of all citations and quotations in their work product.
Copy-pasting citations across matters spreads hallucinations firm-wide; re-verify every carried-forward cite before filing.
Record details
What the record establishes about AI use
Court noted risk of miscitations patched from artificial intelligence.
Memorandum and Order on defendant's motion to dismiss and motion to strike, issued by the U.S. District Court for the Eastern District of Pennsylvania.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
5 citation, quotation, or authority issues are recorded in the source dataset.
- 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.
Questions this record answers
- What happened in Nydia Rosario v. Liberty Mutual Personal Insurance Company?
- The court directed defense counsel to share the memorandum with his law firm colleagues to ensure they are on notice regarding citation errors and to prevent future recurrence. No monetary or formal disciplinary sanctions were imposed.
- Why does Nydia Rosario v. Liberty Mutual Personal Insurance Company matter for legal AI risk?
- Copy-pasting citations across matters spreads hallucinations firm-wide; re-verify every carried-forward cite before filing.
- What does the public record establish about Nydia Rosario v. Liberty Mutual Personal Insurance Company?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Nydia Rosario v. Liberty Mutual Personal Insurance Company 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.
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