Courts on AI / Fabricated or misquoted citations
Strong v. Zubha Pop Foods LLC
Appellate Court of Illinois, First District, Third Division · State appellate courts · IL · · 2026 IL App (1st) 242451-U; 2026 WL 1030781 · No. No. 1-24-2451 · order
The Appellate Court of Illinois, First District on 2026-04-15 struck the defective brief after finding Centient AI links, false quotations, and numerous nonexistent authorities. The self-represented plaintiff filed an opening brief with one fabricated case citation and two mischaracterized case citations, including Dunn v. Old Orchard Ctr.
- Disposition
- The plaintiffs’ briefs were struck and the appeal from summary judgment for defendant was dismissed for failure to comply with Illinois Supreme Court Rule 341; additional sanctions were declined.
- Recorded conduct
- The pro se plaintiffs filed opening and reply briefs with repeated hallucinated citations, references to Centient AI, and abundant fictitious holdings and quotations; after their first briefs were struck and they were allowed to refile, they continued to rely on hallucinated authority and did not respond to two sanctions motions. — outcome: dismissal; actor: litigant in person
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
” McCann v. Dart, 2015 Il App (1st) 141291, ¶ 15. “Arguments that do not comply with Rule 341(h)(7) do not merit consideration on appeal and may be rejected by this court for that reason alone. ” Wells Fargo Bank, N. A. v. Sanders, 2015 IL App (1st) 141272, ¶ 43. ¶16Plaintiffs’convolutedbriefsincludeabundantcitationsto both hallucinated cases and fictitious holdings and quotations from existent cases. Plaintiffs’ citations to fictitious authority are too numerous to relay in their entirety. For instance, in their corrected and amended opening brief, plaintiffs cite Dunn v. Old Orchard Ctr. , Ltd. , 306 Ill. App. 3d 75 (1999). STANCE STRONG and KINISHA STRONG... , Not Reported in N.
Authorities cited in the passage: McCann v. Dart, 2015 Il App (1st · N. A. v. Sanders, 2015 IL App (1st · Dunn v. Old Orchard Ctr. · Plaintiffs cited Dunn v. Old Orchard Ctr., Ltd., 306 Ill. App. 3d 75 (1999) for a proposition the actual case (People v. Ma · Plaintiffs cited Arnold v. Hoyt, 384 F. Supp. 566 (1974) and quoted language not found in the actual opinion · Inc. v. Dussault and the quoted passage is absent · Fausett v. Walgreen Co' with no supporting citation or record
compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub
Hugging Face