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Courts on AI / Fabricated or misquoted citations

Ella and Ramin LLC v. Travelers Insurance Company

United States District Court for the Northern District of Illinois · Federal district courts · IL · · 2026 WL 891866 · No. 24-cv-07870 · order

On 2026-03-31, U.S. District Court for the Northern District of Illinois denied the sanctions motion and dismissed nonparty Travelers-related defendants while noting the movant’s admitted AI use and repeated legal misstatements. A self-represented party submitted a complaint with The complaint and sanctions papers cited nonexistent or irrelevant Illinois insurance authorities while relying on admitted AI-drafted legal research.

Disposition
The court granted in part and denied in part defendants’ partial motion to dismiss, dismissed Travelers Insurance Company and Schnitzer with prejudice, granted plaintiff’s sur-reply motion, and denied plaintiff’s Rule 11 motion.
Recorded conduct
Ghayoori’s response brief cited cases that did not support the asserted propositions, including Harris v. One Hope United, and repeatedly cited Heritage Common Partners v. Village of Summit using two Illinois reporter citations that led to no Illinois case by that name. — outcome: noted, no consequence; 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.

The motion is based on a sentence in Defendants’ reply brief identifying legal errors in Ghayoori's response brief and suggesting that they were caused by Ghayoori's use of generative artificial intelligence (“AI”). Ghayoori's motion is frivolous and therefore denied. Use of AI is not prohibited by this Court's (or this Circuit's) rules. ... Few of the cases Ghayoori cites support the proposition for which he cites them. ... Heritage Common Partners v. Village of Summit ... neither of the two parallel citations lead to a case by that name. Indeed, the Court could not identify any Illinois case with that case name.

compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub