Courts on AI / Fabricated or misquoted citations
Obi v. Cook County, Illinois
United States District Court for the Northern District of Illinois · Federal district courts · IL · · 2026 WL 1678232 · No. 25 C 3096 · order
On 2026-06-10, in Ifeoma Delliane Chinedu Obi v. Cook County, Illinois, et al, the Northern District of Illinois struck the latest defective filing and imposed monetary sanctions for repeated AI-hallucinated arguments and cases. A self-represented litigant cited Andrade v. Arby Concessions, 88 F.4th 1014 (7th Cir. 2023) even though the court found the authority did not exist.
- Disposition
- The court granted Obi’s motion to proceed in forma pauperis on appeal and warned her that continued fake AI-generated authorities could lead to more serious sanctions.
- Recorded conduct
- The pro se plaintiff continued to submit AI-hallucinated arguments and cases after an earlier $5,000 sanction in the same case. This order granted IFP status on appeal and warned against further fake authorities. — outcome: warning; 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.
Obi continues to submit AI hallucinated arguments and cases. On page 7, she asserts that “The district court acknowledged on page 7 that ‘a federal court may hear a claim alleging a state court judgment is void forlackofjurisdiction.’ItcitedAndradev.ArbyConcessions, 88F.4th1014(7thCir.2023).”(Dkt.100at7).Theentiretyof that assertion—the quote, case, and “acknowledgement”—is made up. (Compare id. with Dkt. 88). Obi is a repeat offender on this front. She has continually filed briefs generated by AI that are riddled with fabricated cases and arguments. (Dkt. 97 at 3) (ruling that “[t]he severity of Plaintiff's Rule 11 ongoing and repeated violations warrants sanctions”). She also continues to ignore basic orders and court rules (such as page limit and spacing requirements). (Id. at 1-2).3 Obi claimsthattheCourtdismissedoneofherpositionsrelyingon “a single authority” and “without engagement with binding precedent.” (Dkt. 100 at 8). That is false. The Court cites to, relieson,andengageswith,multiplebindingcases.(Compare id. with Dkt. 88 at 6-8). Obi re-raises her frivolous position that “Docket 14 [i]s the Operative Complaint.” (Dkt. 100 at 10-11, 4).
Authorities cited in the passage: Rule 11
compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub
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