Courts on AI / Fabricated or misquoted citations
Obi v. Cook County
United States District Court for the Northern District of Illinois · Federal district courts · IL · · No. 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
- Obi’s Rule 59(e) motion and replies were struck, and she was ordered to pay $5,000 to the clerk for violating Rule 11.
- Recorded conduct
- Obi generated each brief using AI; her Rule 59(e) motion and replies contained AI hallucinations, including 13 hallucinated cases, quotes, and statements in the motion, a nonexistent Andrade case, fabricated language from Marshall and from the court’s prior order, and similar violations after at least 17 earlier fake items. — outcome: fine; actor: litigant in person; $5,000
- 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.
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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