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Courts on AI / Fabricated or misquoted citations

Noble v. WMC Mortgage Corp.

Appellate Court of Illinois, First District · State appellate courts · IL · · 2026 IL App (1st) 251168-U · No. 1-25-1168 · order

Fabricated or misquoted citations

The Illinois Appellate Court affirms denial of Sanja Noble’s petition and addresses a hallucinated citation in her self-represented brief. The order says Noble cited Ferguson v. Georges, but the reporter citation corresponded to People v. Mott and did not support the standard of review.

Disposition
The court affirmed the denial of Noble's petition and noted a hallucinated citation in her brief.
Recorded conduct
Self-represented appellant cited Ferguson v. Georges at a reporter location that actually contained People v. Mott and did not support her standard-of-review point. — 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.

Arguments that are unsupported by citation do not meet the requirements of Rule 341(h)(7) and are procedurally defaulted. Wing, 2016 IL App (1st) 153517, ¶11. We also note that Noble’s brief contains a “hallucinated” citation on page 10, which occurs when AI-generated responses are used and not verified. See In re Baby Boy, 2025 IL App (4th) 241427, ¶¶ 102-105. She cites Ferguson v. Georges, 389 Ill. App. 3d 543, 553-54 (2010) to state the standard of review for the circuit court’s denial of leave to amend. However, our research has determined that the citation is actually contained within People v. Mott, 389 Ill. App. 3d 539 (2009) and does not address the standard of review relied on.

Authorities cited in the passage: Ill. S. Ct. R. 341(h)(7) · Wing v. Chicago Transit Authority, 2016 IL App (1st) 153517 · In re Baby Boy, 2025 IL App (4th) 241427 · Ferguson v. Georges, 389 Ill. App. 3d 543 (2010) · People v. Mott, 389 Ill. App. 3d 539 (2009)

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub