Williams v. Chicago Board of Education

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.