Courts on AI / Fabricated or misquoted citations
In re M.H., M.L., and M.H.
Appellate Court of Illinois, First District, Fourth Division · State appellate courts · IL · · 2026 IL App (1st) 250013-U · No. No. 1-25-0013 · opinion
On 2026-05-28, in In re M.H., M.L., and M.H., Minors, Appellate Court of Illinois, First District ordered mother to show cause within fourteen days why sanctions should not be imposed for fictitious authorities. Counsel filed a response using nonexistent or hallucinated authorities and authorities used for propositions they did not support.
- Disposition
- The court affirmed the circuit court’s wardship and custody orders and simultaneously issued a rule to show cause to Mother’s counsel regarding the brief’s fictitious case holdings.
- Recorded conduct
- Mother’s counsel filed a brief that misstated facts or holdings of cited cases, incorrectly cited other cases, and referenced cases that do not exist. The court issued a rule to show cause to counsel. — outcome: pending; actor: lawyer
- 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.
The Public Guardian points out that, throughout her brief, the Mother misstates the facts or holdings of cases she citedinsupportofherarguments,incorrectlycitesothers,and referencescasesthatdonotexist.ThePublicGuardianargues that the Mother's reliance on fictitious case holdings violates Illinois Supreme Court Rule 341(h)(7) (eff. Oct. 1, 2020) and asks us to find the Mother's arguments forfeited. “ ‘[B]ecause the merits of the case can be ascertained from the record and we have the benefit of *** cogent brief[s]’ from the State and the Public Guardian, we will consider the merits” of the Mother's arguments. In re Es. C., 2021 IL App (1st) 210197, ¶ 13 (quoting Antonson v. Department of Human Services, 2021ILApp(1st)192272-U,¶18).However,simultaneously with this decision, we issued a rule to show cause order to the Mother's counsel, requiring her to file a response addressing these issues. In the event we find sanctions are warranted, we will issue a separate written order imposing the sanction. In re M.H., M.L., and M.H., Minors (The People of the State of Illinois, Petitioner-Appellee,..., Not Reported in N.E. Rptr.
Authorities cited in the passage: Antonson v. Department of Human Services, 2021ILApp(1st) · Rule 341(h)(7)
compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub
Hugging Face