Courts on AI / Fabricated or misquoted citations

Hulvat v. Gumina

Appellate Court of Illinois, Third District · State appellate courts · IL · 2026-04-09 · 2026 IL App (3d) 240628-U; 2026 WL 963201 · No. Appeal No. 3-24-0628 · order

Fabricated or misquoted citations

On 2026-04-09, Illinois Appellate Court, Third District denied dismissal and striking of the appellate brief but awarded appellees $3,178 in attorney fees for responding to the AI-produced brief. A self-represented party submitted an appellate brief with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including In re Marriage of Lehr.

Disposition: The circuit court’s judgment was affirmed, and Hulvat was ordered to pay Gumina and STG $3,178 in appellate attorney fees and costs for addressing the AI violations.
Recorded conduct: Hulvat’s pro se initial brief cited nine nonexistent cases and fictitious holdings; he acknowledged that the improper citations resulted from using generative AI and filed an amended brief. — outcome: costs order; actor: litigant in person; $3,178
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.

Robert to show cause as to why he Boy, 2025 IL App (4th) 241427, ¶ 57. Our supreme should not be sanctioned based on his violations of Illinois court's policy authorizes the use of AI when compliant Supreme Court rules and AI policy by citing nonexistent with legal and ethical standards. Ill. Sup. Ct., Illinois authorities and fictitious holdings in his appellate brief. Supreme Court Policy on Artificial Intelligence (Jan. 1, Before us are defendants Gumina and STG's request to strike 2025), https://ilcourtsaudio.blob.core.windows.net/antilles- Robert's brief and their petition for attorney fees. resources/resources/ e43964ab-8874-4b7abe4e-63af019cb6f7/Illinois ¶ 29 Robert's initial brief included citations to nine %20Supreme%20Court%20AI%20Policy.pdf (AI Policy). nonexistent cases (Bjorlin v. Aluminum Co. of America, 261 To adhere to these standards, the policy forewarns that “[a]ll Ill. App. 3d 552 (1994); In re Estate of Drawve, 119 Ill. App. users must thoroughly review AI-generated content before 2d 487 (1970); In re Marriage of Lewis, 213 Ill. App. 3d submitting it in any court proceeding,” that “[u]nsubstantiated 1042 (1991); In re Marriage of Royster, 278 Ill. App. 3d *** AI-generated content that *** obscures truth-finding ROBERT S. HULVAT, Plaintiff-Appellant, v. JULI GUMINA,..., Not

Court document: ilcourtsaudio.blob.core.windows.net
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 at ilcourtsaudio.blob.core.windows.net; quoted passage confirmed. Re-coded from the document 2026-09-08 (independent second read).

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