What was hallucinated

Fabricated: Case Law | Nonexistent case cited in briefs; court verified no such docket or decision exists. || Fabricated: Case Law | Fabricated quote attributed to a nonexistent case; court found no Illinois, other state, or federal decision contains it. || Fabricated: Case Law | Nonexistent case admitted by counsel after rule to show cause. || Fabricated: Case Law | Nonexistent case admitted by counsel after rule to show cause. || Fabricated: Case Law | Nonexistent case used to support a Faretta inquiry requirement; court noted no Illinois case imposes Faretta in parental rights cases. || Fabricated: Case Law | Nonexistent case admitted by counsel after rule to show cause. || Fabricated: Case Law | Nonexistent case admitted by counsel after rule to show cause. || Fabricated: Case Law | Nonexistent case cited to support self-representation/de novo review; later 'replacement' case did not support the proposition. || Fabricated: Case Law | Nonexistent case cited for ineffective-assistance principles; later 'replacement' case did not support the proposition. || Misrepresented: Case Law | Real case invoked in response as supporting self-representation/de novo review; court found it does not address those issues. || Misrepresented: Case Law | Real case invoked in response as supporting Strickland ineffective-assistance standard; court found it does not discuss ineffective assistance. || False Quotes: Case Law | Quote misattributed to an existing case; court confirmed the case contains no such language and does not discuss incarceration.

Details

Counsel was sanctioned for citing eight nonexistent cases in briefs filed on behalf of his client, in an appeal concerning the termination of parental rights. The court found that Counsel violated Illinois Supreme Court Rule 375 by submitting fictitious case citations generated by AI without verification. As a result, he was ordered to disgorge $6,925.62 received for his work on the appeal and pay an additional $1,000 in monetary sanctions. The court also directed that a copy of the opinion be sent to the Illinois Attorney Registration and Disciplinary Commission.

Sanction teardown · CA Illinois, USA · 2025-07-21

In re Boy

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)

Nonexistent case cited in briefs; court verified no such docket or decision exists.
Fabricated (Case Law)

Fabricated quote attributed to a nonexistent case; court found no Illinois, other state, or federal decision contains it.
Fabricated (Case Law)

Nonexistent case admitted by counsel after rule to show cause.
Fabricated (Case Law)

Nonexistent case admitted by counsel after rule to show cause.
Fabricated (Case Law)

Nonexistent case used to support a Faretta inquiry requirement; court noted no Illinois case imposes Faretta in parental rights cases.
Fabricated (Case Law)

Nonexistent case admitted by counsel after rule to show cause.
Fabricated (Case Law)

Nonexistent case admitted by counsel after rule to show cause.
Fabricated (Case Law)

Nonexistent case cited to support self-representation/de novo review; later 'replacement' case did not support the proposition.
Fabricated (Case Law)

Nonexistent case cited for ineffective-assistance principles; later 'replacement' case did not support the proposition.
Misrepresented (Case Law)

Real case invoked in response as supporting self-representation/de novo review; court found it does not address those issues.
Misrepresented (Case Law)

Real case invoked in response as supporting Strickland ineffective-assistance standard; court found it does not discuss ineffective assistance.
False Quotes (Case Law)

Quote misattributed to an existing case; court confirmed the case contains no such language and does not discuss incarceration.

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

Attorney ordered to disgorge payment and pay monetary sanctions (monetary penalty: 7925 USD.)

Additional detail

Counsel was sanctioned for citing eight nonexistent cases in briefs filed on behalf of his client, in an appeal concerning the termination of parental rights. The court found that Counsel violated Illinois Supreme Court Rule 375 by submitting fictitious case citations generated by AI without verification. As a result, he was ordered to disgorge $6,925.62 received for his work on the appeal and pay an additional $1,000 in monetary sanctions. The court also directed that a copy of the opinion be sent to the Illinois Attorney Registration and Disciplinary Commission.

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.

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Source: https://www.damiencharlotin.com/documents/605/in_re_Boy_USA_July_21_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).