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Courts on AI / Fabricated or misquoted citations

Ifeoma Delliane Chinedu Obi v. Cook County, Illinois, et al. (1)

U.S. District Court for the Northern District of Illinois · Federal district courts · IL · · No. 25 C 3096 · opinion

On 2026-04-09, U.S. District Court for the Northern District of Illinois struck the motion and imposed a $4,999 sanction for repeated AI-generated fake cases, quotations, and statements of law and fact. A self-represented party submitted a complaint with 13 false quotations and fabricated or nonexistent authorities, including Marshall v. Marshall and Andrade v. Arby Concessions.

Disposition
The court struck the motion and imposed a $4,999 sanction for repeated AI-generated fake cases, quotations, and statements of law and fact.
Recorded conduct
The complaint used 13 false quotations and fabricated or nonexistent authorities, including Marshall v. Marshall and Andrade v. Arby Concessions, which the court found nonexistent, misquoted, or unsupported. — outcome: sanctions; actor: litigant in person; $4,999
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.

such possibility. Plaintiff generated each brief using AI. Plaintiff’s motion is riddled with AI hallucinations, made up cases, quotes, and statements of law and fact. (Dkt. 90); (see also Dkt. 92-1) (identifying 13 hallucinated cases, quotes, and statements of law). For example, Plaintiff quotes Marshall v. Marshall, 547 U.S. 293 (2006) for the rule that “Federal courts may exercise jurisdiction even when the case touches upon matters traditionally reserved to state law, where federal rights are at issue.” (Dkt. 90 at 3). That quoted language is not in Marshall. Plaintiff cites Andrade v. Arby Concessions, 88 F.4th 1014, 1018 (7th Cir. 2023) to dispute the Court’s Order dismissing her complaint. (Dkt. 90 at 6). “Andrade” is not a real case. Plaintiff’s reliance on AI hallucinations is not limited to made up cases either. Plaintiff conjures up new language from this Court’s prior orders as well. Plaintiff asserts that “Page 7 [of the Court’s November 18, 2025, Order] explicitly references that ‘a federal court may hear a claim alleging a state court judgment is void for lack of jurisdiction,’ which is precisely the central and repeated allegation raised by Plaintiff.” (Dkt.

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