Nydia Rosario v. Liberty Mutual Personal Insurance Company
E.D. Pennsylvania · Feb 13, 2026
- Jurisdiction
- federal
- Court
- E.D. Pennsylvania
- Record ID
- nydia-rosario-v-liberty-mutual-personal-insurance-company-2026-02-13
- Observed outcome
- The court ordered defense counsel to share the memorandum with his law firm colleagues to ensure future citation accuracy.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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 || Misrepresented: Case Law | Incorrect reporter volume number for a Third Circuit unpublished opinion: counsel cited '56 F. App'x 133' instead of the correct '506 F. App'x 133' for Smith v. State Farm Auto.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.
Copy-pasting citations across matters spreads hallucinations firm-wide; re-verify every carried-forward cite before filing.
Failure modes and consequences
- Hallucinated_case_law
- Citation_error
- Copy_paste_error
- Lack_of_diligence
- Fabricated Quotes
- Misrepresented Authority
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Court noted risk of miscitations patched from artificial intelligence.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Assign a responsible reviewer for AI-assisted research and drafting.
- Retain a matter-level record of source checks and corrections.