⚡ CASE DIGEST
Idris Abdus Saber v. Navy Federal Credit Union — Pennsylvania Superior Court, 14 January 2026
A Pennsylvania car loan dispute reached the Superior Court with attorney submissions citing cases generated by large language models (LLMs) that do not exist. Westlaw editors flagged the opinion explicitly for LLM-generated non-existent citations — one of the first state-level appellate courts to use ‘LLM’ terminology.
Why it matters: State appellate courts are now using the term ‘large language model’ in published opinions. The AI hallucination problem has reached every level of the American court system — trial, appellate, and state.
Category: Hallucinations & Sanctions | Jurisdiction: USA | Read time: 5 min
Case at a Glance
| Full Citation | Idris Abdus Saber v. Navy Federal Credit Union, No. 2449 EDA 2024 (Pa. Super.) |
| Court | Superior Court of Pennsylvania |
| Date of Decision | 14 January 2026 |
| Category | AI Hallucinations & Sanctions |
| Jurisdiction | USA |
| AI Tool Used | Large Language Model / Generative AI (unspecified) |
| Judgment / Order | 2026 PA Super 7, 2026 WL 194332 |
Background
Idris Abdus Saber purchased a 2020 Jeep Grand Cherokee using a loan from Navy Federal Credit Union. The loan was conditional on a security lien on the vehicle, and the underlying dispute concerned loan terms, lien registration, and the subsequent repossession or title complications. The case reached the Pennsylvania Superior Court on appeal, where counsel’s submissions were found to contain LLM-generated citations to non-existent cases.
The AI Issue
The court’s published opinion prompted Westlaw editors to insert an explicit note that the decision contains citations generated by a large language model that refer to cases that do not actually exist. This makes it one of the earliest state-level appellate decisions to be annotated with the specific ‘LLM’ terminology — signalling that the hallucination problem has permeated every tier of the American judicial system.
What the Court Decided
- The Pennsylvania Superior Court adjudicated the car loan dispute on its merits.
- The published opinion was annotated by Westlaw with an LLM hallucination warning [professional accountability record created].
- The use of ‘large language model’ terminology in the annotation signals judicial awareness of the specific technology involved [LLM liability].
- The decision extends the AI hallucination record from federal courts to state appellate courts.
Key Quote (Westlaw Editor’s Note)
“Editor’s Note: This decision contains discussion of citation references that are incorrect or do not actually exist. These invalid citations appeared in the original court opinion and have been preserved as written since they are part of the official court record.”
— Westlaw Editorial Note, Saber v. Navy Federal Credit Union, 2026 WL 194332
The India Angle
Indian Law Equivalent: Indian courts have not yet imposed AI-specific sanctions, but the duty of verification is embedded in Rule 15 of the Bar Council of India Rules (duty not to mislead the court) and the Contempt of Courts Act, 1971. Fabricated citations — whether AI-generated or otherwise — would constitute contempt before any Indian court.
Bar Council Rules: Bar Council of India Rule 15 requires advocates not to mislead the court. Submitting an AI-generated citation without verification is a clear breach. Disciplinary proceedings before the State Bar Council could follow, including suspension or removal from the roll.
Practical Advice for Indian Advocates: Verify every AI-budgeted case citation on SCC Online, Manupatra, or IndianKanoon before filing. Never rely on a citation you have not personally confirmed exists and says what the AI claims it says. AI hallucinations are a global phenomenon and Indian courts will follow the same enforcement trajectory.
Quick Takeaways
- The AI hallucination problem has reached state appellate courts — every level of the American judiciary is now affected.
- The term ‘large language model’ is now appearing in court records — judges and court publishers understand the technology.
- Indian High Courts and the Supreme Court of India will face the same trajectory as AI tools become more widely used in Indian legal practice.