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Pennsylvania · federal district court · 2026

Florian v. O'Neill

District Court, M.D. Pennsylvania, 29 January 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · M.D. Penn.

  1. Court. District Court, M.D. PennsylvaniaCOURT
  2. Level. federal district courtLEVEL
  3. Date. 29 January 2026DATED
  4. Docket. No. 1:25-cv-02253DOCKET
  5. Judge. Keli M. NearyJUDGE
  6. Documents. one document, 1 passage quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Docket entry 9, 29 January 2026 · source · PDF · 2 pages

Docket text. ORDER re: Generative Artificial Intelligence ("AI"). Signed by Magistrate Judge Susan E. Schwab on 1/29/26. (ae) (Entered: 01/29/2026)

Mindful of the increased use of Generative Artificial Intelligence (“AI”)—for example, OpenAI’s ChatGPT and Google’s Gemini—and the risk that use of such tools can result in legally or factually incorrect information and unsupported or nonexistent legal citations, IT IS ORDERED that when a party uses Generative AI in the preparation of a document in this case, that party shall file with that document a Certificate of Use of Generative AI in which the party must disclose and certify: 1.

What the text mentions

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Where this fits

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More from District Court, M.D. Pennsylvania, from Pennsylvania, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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