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Courts on AI / Fabricated or misquoted citations

Maslovska v. Shigabetdinova

Appellate Court of Illinois, First District · State appellate courts · IL · · 2026 IL App (1st) 250702-U, 2026 WL 688284 · No. 1-25-0702 · order

Illinois Appellate Court on 2026-03-11 in Kateryna Maslovska v. Ekaterina Shigabetdinova found the self-represented party's brief contained two citation defects involving mischaracterized authority. The court warned both sides to verify authorities and quotations before filing future papers in the challenged filing before resolving the pending matter.

Disposition
The court affirmed and cautioned the parties to comply with the Illinois Supreme Court AI policy.
Recorded conduct
The pro se parties' briefs contained six defective citations: four from defendant and two from plaintiff that did not support the cited propositions or did not exist. — outcome: warning; 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.

App. 3d 677, 682 (1993). true ‘when the judgment order states that the court is fully advised in the premises.’ ” Id. (quoting Dell'Armi Builders, ¶ 13 The parties’ briefs also appear to violate the supreme Inc. v. Johnston, 172 Ill. App. 3d 144, 149 (1988)). court's guidance concerning the use of generative artificial intelligence (AI). See Ill. S. Ct. Policy on AI (eff. Jan. 1, *3 ¶ 17 As noted, the common law record lacks a report 2025). They contain in total six references styled as citations of proceedings or an adequate substitute. This court has no to legal authority—four from defendant and two from plaintiff knowledge of the evidence or arguments presented at trial —that do not support the propositions for which they are and the basis for the court's order, which was entered “after cited or that do not exist at all. We caution the parties to trial,” with all parties present, and the court “being fully comply with the supreme court's policy, which applies to advised.” Because we do not have an adequate record, we pro se litigants. See Ill. S. Ct. Policy on AI (eff. Jan. 1, must therefore presume that the court's decision complied 2025) (“self-represented litigants are accountable for their with the law and had a sufficient factual basis. Foutch, 99 Ill. final work product. All users must thoroughly review AI- 2d at 392. generated content before submitting it in any court proceeding to ensure accuracy ***.”). ¶ 18 For these reasons, we affirm the circuit court's decision. ¶ 14 This court has the discretion to strike noncompliant briefs ¶ 19 Affirmed. and dismiss an appeal for failure to adhere to the supreme Hospital, 2019 IL App (1st) 182348, ¶ 45. However, we will

Authorities cited in the passage: The parties’ briefs also appear to violate the supreme Inc. v. Johnston

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