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Courts on AI / Fabricated or misquoted citations

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

United States District Court for the Northern District of Illinois · Federal district courts · IL · · 2026 WL 1678232 · No. 25 C 3096 · opinion

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 struck the latest defective filing and imposed monetary sanctions for repeated AI-hallucinated arguments and cases.
Recorded conduct
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. — outcome: sanctions; 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 Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub