Shelbert v. Baxter International, Inc.

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

The presumable conclusion was that Tyler had AI review Baxter’s Answer and had it generate his Motion to Strike. While there is not yet a proscription prohibiting this conduct, there is a proscription of filing a brief with citations to cases that do not stand for the asserted proposition. Perez-Castillo v. Blanche, 177 F.4th 837, 848 (7th Cir. 2026). Indeed, “[u]nder this circuit’s standards for professional conduct, lawyers promise that they will not knowingly misrepresent, mischaracterize, misquote, or miscite facts or authorities in any oral or written communication to the court.” ... The Seventh Circuit opinion in Instituto supports neither of these propositions. See Instituto, 858 F.2d at 1265-72. Indeed, the words “affirmative defense” are not even in the opinion. The Court admonishes Tyler for repeatedly citing to a Seventh Circuit decision for a false proposition. AI generated content routinely contains errors—including those that may be difficult to readily ascertain.

Authorities cited in the passage: Perez-Castillo v. Blanche, 177 F.4th 837 (7th Cir. 2026) · Instituto Nacional de Comercializacion Agricola (Indeca) v. Continental Illinois National Bank & Trust Co., 858 F.2d 1264 (7th Cir. 1988) · Instituto Nacional De Comercializacion Agricola (Indeca) v. Cont’l Illinois Nat. Bank & Tr. Co., 576 F. Supp. 985 (N.D. Ill. 1983)