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Courts on AI / Fabricated or misquoted citations

Williams v. Chicago Board Of Education

U.S. District Court for the Northern District of Illinois · Federal district courts · IL · · No. s will be consolidated. See 1:24-cv-11729 · memorandum opinion

On 2026-03-30, U.S. District Court for the Northern District of Illinois ordered counsel to file a statement explaining the nonexistent quotations, the Engquist misstatement, and whether the same source caused other errors. Counsel submitted a response brief with two false quotations, fabricated or nonexistent authorities and mischaracterized authorities.

Disposition
The court ordered counsel to file a statement explaining the nonexistent quotations, the Engquist misstatement, and whether the same source caused other errors.
Recorded conduct
The response brief used two false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including EEOC v. Univ. of Chicago Hospitals and Doe v. Village of Arlington Heights, which the court found nonexistent, misquoted, or unsupported. — outcome: pending; actor: lawyer
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.

Arlington Heights, 782 F.3d 911, 917 (7th Cir. 2015): “not every governmental activity that might incidentally prevent crime constitutes ‘police protection service’ within the meaning of section 4-102.’” Pl.’s Resp. Br. at 9. But this quote does not exist. This kind of totally made-up quotations might very well be hallucinated quotations from generative artificial intelligence. What’s more, the brief severely misrepresents the holdings of several other cases, well beyond just an aggressive reading of a holding. For instance, the brief cites Engquist v. Oregon Department of Agriculture, 553 U.S. 591, 598 (2008), to support Williams’s “class-of-one” equal-protection claim. Pl.’s Resp. Br. at 7. But Enquist held that public employees like Williams cannot bring class-of-one claims. Perhaps there are reasonable explanations for how these problems came to be. But because these issues appear throughout the response brief, the Court requires Williams’s counsel to provide a Statement of Explanation to explain (1) how the three identified problems happened (the two non-existent quotations and the citation to Engquist); and (2) whether the source of the problems caused other similar problems in the response brief. The Statement is due by April 13, 2026. V.

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