Courts on AI / Fabricated or misquoted citations
Scott v. Illinois Human Rights Commission
Appellate Court of Illinois, First District · State appellate courts · IL · · 2026 IL App (1st) 251462 · No. 1-25-1462 · opinion
The Illinois First District affirms dismissal of Kimberly Scott’s discrimination charge and sanctions attorney Mason Cole. The opinion says ChatGPT produced 10 false citations or quotations, fines Cole $15,000 at $1,500 per misstatement, and directs the clerk to send the opinion to the ARDC.
- Disposition
- The court affirmed the Commission's dismissal, fined attorney Mason Cole $15,000, and referred the opinion to the ARDC.
- Recorded conduct
- Attorney used ChatGPT in appellate briefing that contained four false statutory quotations, one nonexistent case, and five unsupported case quotations or principles. — outcome: sanctions; actor: lawyer; $15,000
- 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 also sanction petitioner’s attorney Mason Cole for submitting briefs containing false citations and quotations that are the product of artificial intelligence (AI) hallucinations. ... Petitioner’s briefs also contain false case citations. One such case, “Harris v. Illinois Human Rights Comm’n, 2022 IL App (1st) 210454,” does not exist at all. The citation 2022 IL App (1st) 210454-U leads to a criminal case named People v. Riley-Palmer. ... Citations of fictitious legal authority do not automatically justify striking a brief and dismissing an appeal. ... However, we must address petitioner’s attorney’s pattern of presenting multiple fabricated quotes of statutory language and case citations. ... On June 30, 2026, we ordered petitioner’s attorney Mason Cole to file a response explaining the false quotations and citations in his briefs by July 14, 2026. Attorney Cole filed his response on July 2, 2026, 12 days early. His response concedes that all the quotations and citations set out above are false for the reasons we have explained. Attorney Cole states that he “frequently use[s] a premier corporate subscription of ChatGPT” to “synthesize complex matters,” including this case. ... We order attorney Cole to pay a $15,000 fine to the clerk of the Appellate Court, First District, within 30 days of this opinion. ... Attorney Cole’s briefs contain a total of 10 false citations: 4 false statutory quotations, 1 nonexistent case, and 5 cases that exist but do not contain the cited principle or quoted language. This sanction reflects a $1,500 fine for each false citation and quotation. ... The fact that AI hallucinated these citations does not mitigate their falsehood. AI-hallucinated citations are no different than false citations an attorney could create from his own imagination. ... In addition, the clerk of the Appellate Court, First District, shall send a copy of this opinion to the ARDC.
Authorities cited in the passage: Ill. S. Ct. R. 375 · Ill. S. Ct. R. 341 · Harris v. Illinois Human Rights Comm'n, 2022 IL App (1st) 210454 · People v. Riley-Palmer, 2022 IL App (1st) 210454-U · In re Baby Boy, 2025 IL App (4th) 241427 · Couvrette, 2025 WL 4109655 · Noland v. Land of the Free, L.P., 336 Cal. Rptr. 5th 426 (Ct. App. 2025) · Illinois Supreme Court Policy on Artificial Intelligence
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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