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Incident Tracker / United States (state)

Noble v. WMC Mortgage Corp., 2026 IL App (1st) 251168-U

·Appellate Court of Illinois, First District·US-STATEWarning

In Illinois, self-represented litigant Sanja Noble's mortgage appeal brief included a hallucinated citation to Ferguson v. Georges for the standard of review. The Appellate Court found the citation actually led to People v. Mott, declined to strike the brief, disregarded unsupported assertions and affirmed denial of her petition.

Court
Appellate Court of Illinois, First District
Date
2026-08-28
Who used the AI
Litigant in person
AI tool
Not identified in the record
Conduct
Self-represented appellant Sanja Noble cited Ferguson v. Georges, 389 Ill. App. 3d 543, for the standard of review. The court found the citation led to People v. Mott instead and described it as a hallucinated citation that can occur when AI-generated responses are not verified.
Outcome
Warning
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-04

What was fabricated or misused

  • Ferguson v. Georges, 389 Ill. App. 3d 543, 553-54 (2010) — citation actually appeared within People v. Mott, 389 Ill. App. 3d 539 (2009), and did not address the standard of review

What the court said

“Noble’s brief contains only conclusory statements for those issues she chose to address, but no argument directly related to the denial of her section 2-1401 petition.”
Appellate Court of Illinois, First District, ¶ 23
“We also note that Noble’s brief contains a “hallucinated” citation on page 10, which occurs when AI-generated responses are used and not verified.”
Appellate Court of Illinois, First District, ¶ 23
“Thus, we decline to strike plaintiff’s brief and will not dismiss the appeal.”
Appellate Court of Illinois, First District, ¶ 25

Timeline

  1. SQD Revocable Living Trust filed a pro se verified complaint.
  2. Circuit court denied Noble leave to file a second amended complaint with prejudice.
  3. Noble moved for leave to file a third amended complaint.
  4. Circuit court denied Noble’s section 2-1401 petition.
  5. Noble filed a notice of appeal.
  6. Appellate court affirmed and identified the hallucinated citation.

Why this case matters

Noble adds an Illinois appellate example involving a self-represented appellant, not counsel. Unlike Mata v Avianca and Booker v Kroger, the court did not impose money sanctions or strike the filing. It treated the fake cite as one defect in a broader Rule 341 problem and decided the appeal because the issues and opposing brief made review possible. The order is useful because it names the verification failure in a pro se mortgage appeal and connects Illinois appellate briefing rules with AI hallucinations without creating a per se dismissal rule.

Practice note

Before filing an Illinois appellate brief, verify every cited case in an official reporter or a recognised legal database, then confirm the cited pages support the exact standard of review. Pro se status does not relax Rule 341(h)(7). Unsupported assertions should be removed or tied to record citations and real authority before filing.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Noble v. WMC Mortgage Corp., 2026 IL App (1st) 251168-U”, safelegalai.com/tracker/noble-v-wmc-mortgage (accessed 2026-10-07). Data: CC BY 4.0.

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