Courts on AI / Fabricated or misquoted citations
Sani v. Institute for Human Reproduction
Appellate Court of Illinois, First District · State appellate courts · IL · · 2026 IL App (1st) 252264-U · No. 1-25-2264 · order
The Illinois Appellate Court affirms dismissal of Lemna Sani’s complaint and admonishes her about a nonexistent citation in her self-represented opening brief. The court says Helm v. Illinois Central Railroad does not exist and that the reporter citation leads to People v. Hardy, an unrelated criminal case.
- Disposition
- The court affirmed dismissal and admonished the self-represented appellant about nonexistent or unsupported citations.
- Recorded conduct
- Self-represented appellant cited nonexistent Helm v. Illinois Cent. R.R.; the reporter citation led to People v. Hardy and did not address judicial notice. — 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.
We are particularly troubled by the fact that one of her case citations in her opening brief (as IHR notes) does not exist: “Helm v. Illinois Cent. R.R.” does not appear in any reported case in this state, and the precise citation (again, as IHR points out), “142 Ill. App. 3d 108 (1986),” is for a criminal case entitled, “People v. Hardy,” which again contains no discussion of judicial notice. Although we do not know for certain whether this citation was the result of an artificial intelligence (AI) “hallucination,” Sani should be aware that this court is growing increasingly impatient with the patently improper practice of submitting citations of authority that neither exist nor even arguably support the claim on appeal. See, e.g., Scott v. Illinois Human Rights Comm'n, 2026 IL App (1st) 251462, ¶ 56 (imposing a $15,000 fine on an attorney whose brief contained “10 false citations”). Although Sani is proceeding pro se, she must comply with the same rules and will be held to the same standards as licensed attorneys.
Authorities cited in the passage: Helm v. Illinois Cent. R.R., 142 Ill. App. 3d 108 (1986) · People v. Hardy, 142 Ill. App. 3d 108 (1986) · Scott v. Illinois Human Rights Commission, 2026 IL App (1st) 251462
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