Skip to main content
Citation Safe

Was Carla Bender 4thdistrict Appellate Ct. on the other side of your case?

Check their next brief before they file — Opposition Check verifies every citation in a filed brief for $49, no signup. Get Opposition Check →

Carla Bender 4thdistrict Appellate Ct. v. Julian S.

Court
CA Illinois
Jurisdiction
USA
Decided
2025-08-04
AI tool
Implied
Outcome
Monetary sanctions imposed on attorney and report to disciplinary commission
Monetary penalty
1000 USD

What was hallucinated

Fabricated: Case Law | Seven cases of fabricated citations || Misrepresented: Case Law | Cited "one nonprecedential order entered pursuant to Illinois Supreme Court Rule 23(b)(eff. Feb. 1, 2023), that existed but did not stand for the propositions of law for which they were cited". || Fabricated: Case Law | As another instance, Attorney Panichi cited In re D.F., 201 Ill. 2d 476 (2002), in (1) the opening brief for the proposition that "courts must consider whether a parent's disabilities affect their ability to comply with service plans," and (2) the reply brief for the proposition that "a parent's disabilities must be factored into determinations regarding compliance with services."

Details

The appellate court dismissed the appeals due to lack of jurisdiction and ordered respondent's appellate Counsel to pay $1,000 in monetary sanctions for violating Illinois Supreme Court Rule 375 by citing multiple cases that did not stand for the propositions of law for which they were cited. The court also ordered a copy of the decision to be sent to the Illinois Attorney Registration and Disciplinary Commission.Counsel had previously admitted to using AI to prepare briefs in another case (in Re Boy) without thoroughly reviewing the work-product, leading to similar issues. The court found it reasonable to conclude AI was used in this case as well, although not explicitly admitted by Counsel.

Sanction teardown · CA Illinois, USA · 2025-08-04

Carla Bender 4thdistrict Appellate Ct. v. Julian S.

What happened

In CA Illinois, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Seven cases of fabricated citations
  • Misrepresented (Case Law)
    Cited "one nonprecedential order entered pursuant to Illinois Supreme Court Rule 23(b)(eff. Feb. 1, 2023), that existed but did not stand for the propositions of law for which they were cited".
  • Issue
    Fabricated: Case Law | As another instance, Attorney Panichi cited In re D.F., 201 Ill. 2d 476 (2002), in (1) the opening brief for the proposition that "courts must consider whether a parent's disabilities affect their ability to comply with service plans," and (2) the reply brief for the proposition that "a parent's disabilities must be factored into determinations regarding compliance with services."

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Monetary sanctions imposed on attorney and report to disciplinary commission (monetary penalty: 1000 USD.)

Additional detail

The appellate court dismissed the appeals due to lack of jurisdiction and ordered respondent's appellate Counsel to pay $1,000 in monetary sanctions for violating Illinois Supreme Court Rule 375 by citing multiple cases that did not stand for the propositions of law for which they were cited. The court also ordered a copy of the decision to be sent to the Illinois Attorney Registration and Disciplinary Commission.Counsel had previously admitted to using AI to prepare briefs in another case (in Re Boy) without thoroughly reviewing the work-product, leading to similar issues. The court found it reasonable to conclude AI was used in this case as well, although not explicitly admitted by Counsel.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/649/Carla_Bender_v._Julian_S._USA_4_August_2025.PDF, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/649/Carla_Bender_v._Julian_S._USA_4_August_2025.PDF

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checkerBack to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49Sanctions-motion template