Hoagland Family Limited Partnership v. Town of Clear Lake

What the court wrote

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

This case appears to not exist. The reporter citation provided—“521 N.E.2d 1240”—leads to People v. Pira, 521 N.E.2d 1236 (Ill. App. Ct. 1988) (beginning on page 1236, ending on page 1243). The pincite provided—“521 N.E.2d [at] 1244”—leads to Hauk v. Day, 521 N.E.2d 1243 (Ill. App. Ct. 1988) (beginning on page 1243, ending on page 1245). This court has decided several cases with the name “Fox v. Fox,” but none of those cases were decided in 1988. A search of Indiana cases for the quotation Hoagland provided returned no relevant results. Because the “Fox v. Fox” citation and associated quotation do not exist, it is likely they were created using generative artificial intelligence. “Citations to fictitious, AI-generated authority is a growing problem nationwide. Courts have sanctioned both attorneys and pro se litigants for including them in briefs.” Cingel v. Ferreri, 269 N.E.3d 857, 861 (Ind. Ct. App. 2025) (quoting Williams v. Kirch, 268 N.E.3d 284, 288 (Ind. Ct. App. 2025), trans. not sought), trans. not sought. “We caution attorneys and pro se litigants alike against using AI to conduct legal research without independently verifying the citations generated. Judges must be able to rely on the authenticity of the authorities cited by the parties to make just decisions.” Id. (quoting Williams, 268 N.E.3d at 288). Although the Town in its Appeal 1361 briefing brought to Hoagland’s attention the nonexistent citation and quotation, Hoagland failed to explain in its Appeal 1361 reply brief why it cited and quoted a nonexistent source. We remind Hoagland’s counsel of his obligations under the Professional Conduct Rules, particularly his duty to not “knowingly . . . fail to correct a false statement of . . . law previously made to the tribunal,” Prof. Cond. R. 3.3(a)(1).

Authorities cited in the passage: Cingel v. Ferreri, 269 N.E.3d 857 (Ind. Ct. App. 2025) · Williams v. Kirch, 268 N.E.3d 284 (Ind. Ct. App. 2025) · Indiana Professional Conduct Rule 3.3(a)(1)