Twigg v. BSN Sports, Inc., et al.
M.D. Pennsylvania · May 21, 2026
- Jurisdiction
- federal
- Court
- M.D. Pennsylvania
- Record ID
- twigg-v-bsn-sports-inc-et-al-2026-05-21
- Observed outcome
- The court denied the omnibus motion for post-trial relief and ordered Plaintiffs' counsel to show cause why he should not be sanctioned for Rule 11 violations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued an order to show cause against Plaintiffs' counsel, Nicholas W. Mattiacci, regarding potential violations of Federal Rule of Civil Procedure 11. The court found that counsel submitted a brief containing fabricated cases, false quotations, and irrelevant citations, which counsel admitted resulted from the use of artificial intelligence without adequate verification.
The court reasoned that counsel violated Rule 11(b)(2) by failing to perform a reasonable inquiry into the accuracy of legal authorities. The court emphasized that attorneys have a non-delegable duty to verify the existence and validity of citations, and that outsourcing research to AI without verification is inconsistent with professional standards. The court further noted that counsel's attempt to minimize the errors as 'clerical' and shift blame was disingenuous and demonstrated a lack of candor.
This case highlights the judicial expectation that attorneys must independently verify all AI-generated legal research. It serves as a warning that courts will not accept 'clerical error' defenses when counsel fails to confirm the existence and accuracy of cited authorities, particularly when AI is involved in the drafting process.
Failure modes and consequences
- Fabricated Case Law
- False Quotations
- Misrepresented Authority
- Lack Of Verification
- Fake Citations
- Fabricated Quotes
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- Post-trial motion practice following a jury trial, resulting in an order to show cause regarding potential Rule 11 sanctions.
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
Counsel admitted to using AI for drafting.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all AI-generated citations and quotations before filing.
- Conduct independent research to confirm the existence and precedential relevance of every case cited in a brief.
- Avoid relying on AI tools for legal research without human oversight and verification of the underlying source material.
- Ensure that errata sheets or corrections are comprehensive and transparent rather than minimizing the scope of citation errors.