Problems with “Chatbots”

Many legal commentators and publications have noted that there are problems with relying on “generative artificial intelligence” or “large language models” such as “ChatGPT,” which are often referred to (somewhat derisively) as “chatbots.” The problems are usually described as “hallucinations” when a chatbot has been asked a legal question or is asked to draft of legal memo and provides a citation to a court opinion that simply does not exist. But there are other problems that are more subtle and more fundamental.

Chatbots simply manipulate words based on perceived patterns in documents that have been used to “train” them. They have no understanding of the meaning of words or any understanding of legal concepts. So even if you can train a chatbot to not fabricate citations to nonexistent court opinions, there is still no guarantee that it will accurately describe the real court opinions it cites.

This more subtle kind of error is described in Jarrus v. Governor of Michigan, No. 25-cv-11168 (USDC ED Mich. 12/2/2025). In an opinion and order on the possible imposition of sanctions for the use of Chat GPT, Judge F. Kay Behm provides three examples of citations that appeared in a pleading filed by a pro se litigant that were real citations to real court opinions but were cited for propositions that the opinions did not support. The court explained the problem as follows:

“[A]lthough Chat GPT generated ‘holdings’ that looked like they could plausibly have appeared in the cited cases, in fact it overstated their holdings to a significant degree. And while a litigant might get away with similar overstatements because they could, perhaps, reason their way to showing how a case’s stated holding might extend to novel situations, an LLM does not reason in the way a litigant must. To put it in a slightly different way, LLMs do not perform the metacognitive processes that are necessary to comply with Rule 11. LLMs are tools that “emulate the communicative function of language, not the separate and distinct cognitive process of thinking and reasoning.” Benjamin Riley, Large language mistake, The Verge https://www.theverge.com/ai-artificial-intelligence/827820/large-language-models-ai-intelligence-neuroscience-problems [https://perma.cc/7EHD-PLLZ]. When an LLM overstates a holding of a case, it is not because it made a mistake when logically working through how that case might represent a ‘nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law;’ it is just piecing together a plausible-looking sentence — one whose content may or may not be true.”

Legal publishers are putting together their own generative AI systems which are presumably designed to avoid the fictitious citation problem, but they cannot avoid the problem which is inherent to large language model technology, which is that the systems are not capable of doing any legal reasoning, but are only constructing “plausible-looking sentences” based on the documents that have been used to train them.

With better training methods, document drafting may be an effective use for AI technology (in the late 1980s, I co-authored a document drafting system that used what was then considered AI technology, but was not able to market it successfully), but at this time the use of generative AI for legal research or drafting legal briefs or memoranda should be considered only with an understanding of it’s considerable limitations.

Electronic Wills Co-Sponsorship Memo

As previously reported, the Pennsylvania Bar Association, acting on a joint report and recommendation of the Real Property Probate and Trust Law and Elder Law Sections, is now supporting the introduction and passage of legislation authorizing electronic wills and other estate-related documents in Pennsylvania.

A co-sponsorship memo from Lisa Baker, the Senator from District 20, has been circulating since 12/9/2025 asking for support from other Senators for the legislation (which has not yet been introduced).

Applicable Federal Rates for 2025

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HTML Version Copyright 2018-2026 Daniel B. Evans. All rights reserved.

— Short Term Rates for 2025 —

MonthAnnualSemiann.QuarterlyMonthly
Jan.4.33%4.28%4.26%4.24%
Feb.4.34%4.29%4.27%4.25%
March4.31%4.26%4.24%4.22%
April4.16%4.12%4.10%4.09%
May4.05%4.01%3.99%3.98%
June4.00%3.96%3.94%3.93%
July4.12%4.08%4.06%4.05%
Aug.4.03%3.99%3.97%3.96%
Sept.4.00%3.96%3.94%3.93%
Oct.3.81%3.77%3.75%3.74%
Nov.3.69%3.66%3.64%3.63%
Dec.3.66%3.63%3.61%3.60%

— Mid Term Rates for 2025 —

MonthAnnualSemiann.QuarterlyMonthly
Jan.4.24%4.20%4.18%4.16%
Feb.4.52%4.47%4.45%4.43%
March4.46%4.41%4.39%4.37%
April4.21%4.17%4.15%4.13%
May4.10%4.06%4.04%4.03%
June4.07%4.03%4.01%4.00%
July4.19%4.15%4.13%4.11%
Aug.4.06%4.02%4.00%3.99%
Sept.4.04%4.00%3.98%3.97%
Oct.3.87%3.83%3.81%3.80%
Nov.3.83%3.79%3.77%3.76%
Dec.3.79%3.75%3.73%3.72%

 — Long Term Rates for 2025 —

MonthAnnualSemiann.QuarterlyMonthly
Jan.4.53%4.48%4.46%4.44%
Feb.4.86%4.80%4.77%4.75%
March4.82%4.76%4.73%4.71%
April4.61%4.56%4.53%4.52%
May4.62%4.57%4.54%4.53%
June4.77%4.71%4.68%4.66%
July4.90%4.84%4.81%4.79%
Aug.4.82%4.76%4.73%4.71%
Sept.4.83%4.77%4.74%4.72%
Oct.4.73%4.68%4.65%4.64%
Nov.4.62%4.57%4.54%4.53%
Dec.4.55%4.50%4.47%4.46%

PBA Supports Inheritance Tax Exemption for All 529 Accounts

On November 21, 2025, the House of Delegates of the Pennsylvania Bar Association approved a joint recommendation of the Real Property, Probate and Trust Law and Elder Law Sections of the PBA to support HB 256, which will exempt from Pennsylvania inheritance tax all educational savings accounts (usually known as “529 accounts” or “529 plans”), regardless of whether the account was created under the laws of Pennsylvania or another state.

The complete Report and Recommendation of the two PBA sections explains the background of HB 256, which is that the Inheritance and Estate Tax Act does not include any exemption from inheritance tax for educational savings plans described in section 529 of the Internal Revenue Code. Pennsylvania has enacted its own plan for educational savings account to qualify under section 529, and that statute exempts accounts under that plan from all taxation, including inheritance tax. Because there is no general exemption for 529 plans, educational savings accounts created under the plans of other states remain subject to inheritance tax.

One Orphans’ Court judge has held that an inheritance tax exemption only for Pennsylvania 529 accounts violates the uniformity clause of the Pennsylvania Constitution. Calihan Estate, 2 Fid.Rep.4th 1, No. 0024 of 2021 (Allegheny O.C. 11/7/2023). However, the Pennsylvania Department of Revenue is not following that decision for estates in other counties.

HB 256 would amend the inheritance tax act to exempt from inheritance tax all 529 accounts, regardless of what state law was used to create the account, and the PBA now supports that legislation (or any similar legislation that might be proposed in the future).

[12/11/2025 Revision: The original version of this post included a link to the report and recommendation of the PBA two sections, and that link has been deleted at the request of the PBA.]

Act 50 of 2025 Increases Some Amounts Payable without Letters

House Bill 1176 has passed both houses of the legislature and has been signed into law by the governor, becoming the Act of November 24, 2025, No. 50. The two sections of the act can be summarized as follows:

Section 1 of the act amends 20 Pa.C.S. § 2103(a)(6) to change the ultimate intestate heir (who would take in the event that there is no surviving spouse and no surviving issue, parents, brothers or sisters, issue of brothers or sisters, grandparents or issue of grandparents) from the Commonwealth of Pennsylvania to an “endowed community fund” located in the municipality, school district, or county in which the decedent resided. If there is no such “endowed community fund” (as further defined by the statute), the last intestate heir is the Commonwealth. This part of the act takes effect in 60 days (which presumably means it applies to the estates of intestates dying 60 days or more after enactment, because intestate shares are usually determined based on the facts and laws as of the date of death).

Section 2 of the act amends two of the subsections of 20 Pa.C.S. § 3101 (“Payments to family and funeral directors”) to increase the amounts that may be paid without any grant of letters:

  • In subsection (b) (“Deposit account”), the maximum total amount on deposit in the name of the decedent at a bank or other financial institution that can be paid to a funeral director or family member is increased from $10,000 to $20,000. This change is effective in 60 days, which may refer to the date of the payment and not the date of death.
  • In subsection (e) (“Unclaimed property”), the maximum amount held by the State Treasurer as unclaimed property of a decedent that can be paid to a family member without any grant of letters is increased from $11,000 to $20,000. This change is effective in 180 days, which may refer to the date of the claim filed with the Treasurer not the date of death.

The maximum amounts which may be paid under other subsections of § 3101 remain unchanged, so wages, salaries, and employee benefits are still limited to $10,000 under subsection (a), a patient’s care account is still limited to $10,000 under subsection (c), and life insurance payable to the estate is still limited to $11,000 under subsection (d).

New Montgomery County Fee Schedules

Montgomery County has published new fee schedules for the Register of Wills and Clerk of the Orphans’ Court, both effective January 1, 2026. “Register of Wills Fee Schedule; No. 2025-00001” (11/5/2025), 55 Pa.B. 7950 (11/22/2025); “Clerk of Orphans’ Court Fee Schedule; No. 2025-00002” (11/5/2025), 55 Pa.B. 7947 (11/22/2025).

Fiduciary Exception Not Applicable to Civil Action against Beneficiary

The fiduciary exception to the attorney-client privilege does not apply to attorney records relating to a civil action brought by a trustee against one of the beneficiaries to enforce an indemnification agreement entered into for a distribution to that beneficiary, and so those records remain subject to attorney-client privilege. In re: First and Partial Account of Gerald L. Hempt, Trustee for the Max C. Hempt QTIP Trust, ___ A.4th ___, 2025 PA Super 2054 (11/13/2025).

No Breach of Duty by Agent on Sale of Property Placed in Joint Names before Power of Attorney Was Signed

It was not a breach of fiduciary duty for the proceeds of sale of a property to be paid half to the two co-owners, mother and daughter, even though the daughter was the mother’s agent under a general power of attorney, when the mother purchased the property before executing the power of attorney and the addition of the daughter’s name as a co-owner when the property was purchased was solely the decision of the mother. There was also no evidence that the daughter had any role in the sale of the property other than signing a listing agreement that the mother later ratified. Although the grant of a power of attorney may be evidence of a prior confidential relationship, there was no evidence that the daughter had an “overmastering influence” on her mother or that the mother was not making her own decisions about the purchase and sale of the property. A claim by the mother against the daughter for withdrawing money from a joint account was denied because the money deposited to the account came from the daughter, and so the daughter remained the owner of the account during her lifetime. (Other issues addressed by the court included a breach of contract claim, the rights of co-owners of property, evidentiary rulings, and the denial of a claim for punitive damages.) Purcell v. Caples, 1818 EDA 2023, 1963 EDA 2023, 1964 EDA 2023, 1210 EDA 2024 (Pa. Super. 11/14/2025) (non-precedential).

Third Need for Emergency Guardianship

It was an error of law, and so an abuse of discretion, for the Orphans’ Court to deny a third petition for a guardian of the person when there was evidence that the electroconvulsive treatments (“ECT”) that were administered to the incapacitated person (IP) with the consent of the emergency guardian and temporary guardian appointed in accordance with the first two petitions were effective but the IP’s mental illnesses had returned, and so there was a new emergency allowing the use of the emergency guardianship procedure, as well as evidence that the IP would suffer irreparable harm without additional ECT. In re: L.L.H., 1420 MDA 2025 (Pa. Super. 11/14/2025) (non-precedential).