Published opinion, 14 January 2026 · source · PDF · 9 pages
2022). Appellant proffers voluminous argument about the rights of a holder in due course under the PUCC but, absent the purported authority in the non-existent D’Happart ____________________________________________ 3 We may cite to non-published decisions of this Court filed after May 1, 2019 for their persuasive value pursuant to Pa.R.A.P. 126(b).
Here, among other things, Appellant’s contention that he “gave value” is wholly unmoored from the record. Further, as Appellee points out, in addition to the D’Happart citations, Appellant’s brief contains citations to several other cases which “do not exist” and suggests this is due to Appellant’s use of generative artificial intelligence (“generative AI” or “GAI”) to draft his brief. Appellee’s Brief at 17-18.
Appellee’s Brief at 17-18. The Colorado Court of Appeals has explained that “[c]ase names and citations that a GAI tool makes up are known as ‘hallucinations.’” Al-Hamim v. Star Hearthstone, LLC, 564 P.3d 1117, 1119 (Colo.
Cl. 2025) (stating that “[i]t is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs” (citation omitted)). The Al-Hamim Court further stated that “GAI tools are trained using [large language models] that, through a form of machine learning known as deep learning, teach the program how characters, words, and sentences function together.” Al- Hamim, 564 P.3d at 1123 (citations and quotation marks omitted).
The Al-Hamim Court further stated that “GAI tools are trained using [large language models] that, through a form of machine learning known as deep learning, teach the program how characters, words, and sentences function together.” Al- Hamim, 564 P.3d at 1123 (citations and quotation marks omitted). Further, “[a] GAI system can generate citations to totally fabricated court decisions bearing seemingly real party names, with seemingly real reporter, volume, and page references, and seemingly real dates of decision.” Id. (citations and quotation marks omitted); see also Commonwealth v.