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Courts on AI / Fabricated or misquoted citations

Helen Allen v. Cass Casper and Disparti Law Group

United States District Court for the Northern District of Illinois · Federal district courts · IL · · No. No. 25 C 10438 · memorandum opinion

Northern District of Illinois on 2026-03-10 in Helen Allen v. Cass Casper and Disparti Law Group found the self-represented party's brief contained two citation defects, including Krause v. Meyers, Krause and Krause v. Meyers', involving nonexistent authorities, fabricated or misattributed quotations. The court ordered the self-represented party to pay $1,500 for the defective authorities.

Disposition
The court ordered the self-represented party to pay $1,500 for the defective authorities.
Recorded conduct
The self-represented party's brief contained two citation defects, including Krause v. Meyers, Krause and Krause v. Meyers', involving nonexistent authorities, fabricated or misattributed quotations. — outcome: fine; actor: litigant in person; $1,500
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.

that she is representing herself does not relieve her of that duty. Filing a document that contains citations to nonexistent cases, quotes language that comes from no real case, or that contains arguments wholly unsupported by the record violates Rule 11. Allen did just that. This demonstrates that Allen failed to make a reasonable inquiry into the supporting law or facts. This wastes both the parties’ and the Court’s time attempting to locate nonexistent cases and unpack made up factual assertions. The Court sanctions Allen $1,500 for filing false cases and arguments to the Court in violation of Rule 11. See, e.g. Seth Cameron Virgil v. Experian Information Solutions Inc, et al., 2026 WL 401066, at *5 (S.D. Ind. Feb. 12, 2026) (recommending $10,000 sanction for submitting a brief with hallucinated cases); Mid Cent. Operating Eng’rs Health & Welfare Fund v. HoosierVac LLC, 2025 WL 1511211 (S.D. Ind. May 28, 2025) (imposing $6,000 sanctions for briefs containing hallucinated citations); Davis v. Marion Cnty. Superior Ct. Juv. Det. Ctr., 2025 WL 2502308 (S.D. Ind. Sept. 2, 2025) (recommending $7,500 sanction for a brief containing hallucinated citations). 21 Case: 1:25-cv-10438 Document #: 32 Filed: 03/10/26 Page 22 of 22 PageID #:386

Authorities cited in the passage: Krause v. Meyers · Krause · Governmental Interinsurance Exchange v. Judge, 221 Ill. App. 3d 586 · Seth Cameron Virgil v. Experian Information Solutions Inc · Mid Cent. Operating Eng’rs Health & Welfare Fund v. HoosierVac LLC, 2025 WL 1511211 · Davis v. Marion Cnty. Superior Ct. Juv. Det. Ctr., 2025 WL 2502308 · Rule 11

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