Illinois

Ella and Ramin LLC v. Travelers Insurance Company

Misrepresented: Case Law | Plaintiff cited Harris v. One Hope United, Inc., 28 N.E.3d 804 (Ill. 2015) for the proposition that parent and subsidiary may be treated as a single entity, but the case concerns discovery privilege and does not support that corporate-law proposition (misapplied precedent). || Fabricated: Case Law | Plaintiff repeatedly cited 'Heritage Common Partners v. Village of Summit' with 2009 Illinois reporter citations that the court could not locate; court found no Illinois case by that name and the only reported federal opinions by that name were from 1990–1991 and unrelated to the cited propositions.

Williams v. Chicago Board Of Education

False Quotes: Case Law | Response brief included a non-existent quotation attributed to EEOC v. Univ. of Chicago Hospitals; the court found the case contains no such language and called it a 'totally made-up quotation' possibly from generative AI. || False Quotes: Case Law | Response brief included a purported quotation attributed to Doe v. Village of Arlington Heights that the court found does not exist. || Misrepresented: Case Law | Response brief cited Engquist as supporting a 'class-of-one' equal-protection claim, but the court noted Engquist actually holds class-of-one claims do not apply in the public employment context, so the brief misrepresents the case's holding.

Tina Rose v. City of West Frankfort et al.

Helen Allen v. Cass Casper and Disparti Law Group

Fabricated: Case Law | Plaintiff cited a nonexistent case 'Krause v. Meyers' to support malpractice theory; the court found 'Krause' is fabricated and an AI hallucination and rejected reliance on it. || Fabricated: Case Law | Plaintiff cited 'Governmental Interinsurance Exchange v. Judge, 221 Ill. App. 3d 586', which the court determined does not exist and was another AI-generated fabrication.

Hatch v. College Ave Student Loans

Fabricated: Case Law | Plaintiff's counsel cited Horan v. Equifax Info. Servs., LLC to support arguments; the Court could not locate the opinion and ordered counsel to produce a true and accurate copy or explain how the citation was located. || Fabricated: Case Law | Plaintiff's counsel cited Jones v. TransUnion, LLC; the Court was unable to find the cited decision and directed counsel to provide the opinion or a sworn declaration about how the brief was generated.

Bettis v. Gaston

Fabricated: Case Law | Plaintiff cited 'Dvorak v. Metropolitan Pier & Exposition Authority, 941 F.3d 936 (7th Cir. 2019)', which the court (as defendants pointed out) appears not to exist; court flagged this as an AI-style fabricated citation. || False Quotes: Case Law | Plaintiff attributed a quotation to Brooks v. Ross, 578 F.3d 574 (7th Cir. 2009) that does not exist in that opinion; court identified this as a false quotation. || Misrepresented: Case Law | Plaintiff cited LeBeau v. Taco Bell, Inc., 892 F.2d 605 (7th Cir. 1989) as supporting the two-dismissal rule, but the court found the opinion does not discuss that rule (misrepresented precedent).

[Plaintiff] v. Webb Chevrolet, Inc., et al.

False Quotes: Case Law | Plaintiff attributed a specific quote to Fox v. Heiman that does not appear in that opinion; court noted Fox does not mention section 2-619 or contain the quoted language. || False Quotes: Case Law | Plaintiff asserted Concepcion supports limitations on arbitration protecting consumer claims; court observed Concepcion does not include the propositions plaintiff attributed to it. || False Quotes: Case Law | Plaintiff claimed Kinkel and Gallagher stand for broad public-policy limits on arbitration clauses; court found neither case supports the sweeping propositions plaintiff attributed to them. || Fabricated: Case Law | Plaintiff cited a nonexistent Illinois opinion; court searched and found no case by this name and the cited volume/page corresponded to an unrelated criminal opinion. || Fabricated: Case Law | Plaintiff cited a nonexistent case title/citation; court found the actual opinion at that citation was a different case and no 'Sears v. Illinois Central Savings & Loan' exists. || Fabricated: Case Law | Plaintiff cited a case by name and citation that do not exist in Illinois or elsewhere; court's search returned no such authority. || Fabricated: Case Law | Plaintiff cited a nonexistent opinion and attributed a specific holding; court found no such case or holding at the citation provided. || Fabricated: Case Law | Plaintiff cited a case title/citation that matched other unrelated opinions; court found no support for the claimed arbitration-related holding. || False Quotes: Case Law | Plaintiff quoted language purportedly from Smith v. Airoom that does not appear in the opinion; court found the quoted language and the asserted principles absent from Smith. || False Quotes: Case Law | Plaintiff attributed a holding to Keefe that the case does not contain (re: section 2-619 not a responsive pleading); court found Keefe does not contain the quoted language or discuss section 2-619.

Ravi Kadiyala v. Shellpoint Mortgage Servicing et al.

Fabricated: Case Law | Plaintiff's filing cited a non-existent opinion; the court found the citation did not exist, inferred AI use, and warned of possible Rule 11 sanctions.

Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (2)

Fabricated: Case Law | Plaintiff twice cited a non-existent case Lathan v. Brinkerhoff; court identified it as fictitious and previously warned about it. || Fabricated: Case Law | Plaintiff mis-cited 'City of Chicago v. Matchmaker' (court treated it as an incorrect/fictitious citation in plaintiff's brief). || Fabricated: Case Law | Plaintiff cited 'Oconomowoc v. Greenfield,' a mis-citation distinct from the real Oconomowoc Residential Programs precedent referenced by the court. || Fabricated: Case Law | Plaintiff cited 'Vargas v. Cook Cnty. Sheriff' in his brief; court listed it among the mis-citations in the response. || Misrepresented: Case Law | Plaintiff invoked Bloch v. Frischholz for the proposition that statistical evidence is not required; court explained Bloch does not support that conclusion and was misrepresented.

Illinois SB 1929

Illinois legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Illinois SB 1792

Illinois legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Illinois SB 2203

Illinois legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Illinois SB 2995

Illinois legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Illinois SB 3180

Illinois legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Illinois SB 3263

Illinois legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Illinois SB 3312

Illinois legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Illinois HB 4711

Illinois legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Illinois HB 4799

Illinois legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Illinois HB 4988

Illinois legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

In re S.A., D.H., and B.M., Minors

False Quotes: Case Law | Respondent attributed the quote 'A parent is not required to parrot the agency's exact narrative.' to In re Brianna B.; the court found the quote fictitious and not addressed in that opinion. || False Quotes: Case Law | Respondent cited a fictitious quote from In re A.S., asserting 'Reasonable progress does not require complete agreement with the Department's version of events,' which the court found not present in that decision. || False Quotes: Case Law | Respondent attributed a fabricated quote to In re J.L., claiming 'Parents may dispute details of the incident while still making progress toward correcting the conditions that led to removal,' which the court said J.L. did not address. || False Quotes: Case Law | Respondent drew a fictitious conclusion from In re M.A., quoting that termination "cannot rest on a parent's personality traits or imperfect cooperation unless those conditions prevent the parent from safely parenting," which the court found was not in M.A.

Halpern v. Federal Reserve Bank of New York, et al.

False Quotes: Case Law | Halpern repeatedly attributed a non-existent quotation to Fed. Rsrv. Bank of St. Louis v. Metrocentre Improvement Dist. #1, 657 F.2d 183; the court found the quotation does not appear in that case or elsewhere and called the attribution improper.

Sharky’s Sports Bar, et al. v. Village of Mt. Morris, Illinois, et al.

Misrepresented: Case Law | Court found 'Rowe v. State of Lombard' exists but the reporter volume and first page were represented inaccurately in the Swanlunds' filing; citation details were misreported. || Misrepresented: Case Law | Court found cases called 'O'Sullivan v. City of Chicago' exist but the Swanlunds misreported reporter volume, first page, date, and court; real O'Sullivan cases do not appear to support the cited proposition.

Sean Gottlieb v. Adtalem Global Education

Fabricated: Case Law

Dorsey v. Ponce, et al.

Fabricated: Case Law | Plaintiff cited 'State v. Slowikowski, Ohio 2003,' which the court could not locate and flagged as an invalid/nonexistent citation. || Fabricated: Case Law | Plaintiff cited 'U.S. v. Weaver, 9th Circuit, 2016,' which the court was unable to find and identified as an incorrect or nonexistent citation. || Fabricated: Case Law | Plaintiff cited 'Mackey v. Town of Allendale, 2021,' a citation the court could not locate and treated as invalid/fabricated. || Fabricated: Case Law | Plaintiff cited 'Sanchez v. Dart, 2016,' which the court could not find (noting a different case with that caption exists from 2020), treating the 2016 citation as invalid.

Boyd v. Protestant Memorial Medical Center

Fabricated: Case Law | Plaintiff cited Fleming v. Chicago Transit Authority, 2006 WL 769440 (N.D. Ill. 2006); court determined the citation is inconsistent/non-existent (case filed in 2007) and cannot be located as cited. || Misrepresented: Case Law | Plaintiff cited Bickler v. Senior Lifestyle Corp., 266 F.R.D. 379 as Seventh Circuit/N.D. Ill. authority; court noted the citation is incorrect (Bickler is 266 F.R.D. 379 (D. Ariz. 2010)) and does not support her claimed proposition.

Bryan Pletcher v. Village of Libertyville Police Pension Board

False Quotes: Case Law | Misquoted Roszak as standing for a rule about boards adopting selected experts while ignoring contrary evidence (mischaracterized). || False Quotes: Case Law | Misstated Jones as addressing shift work and cardiovascular conditions (case does not discuss this). || False Quotes: Case Law | Attributed a discussion about genetics affecting treatment effectiveness to Johnston, which the case does not contain. || Misrepresented: Exhibits & Submissions | Relied on Exhibits A–F that plaintiff never introduced to the administrative record and cited non-existent record page numbers. || False Quotes: Case Law | Plaintiff quoted Roszak as prohibiting adoption of selected experts' conclusions while ignoring contrary evidence; court found Roszak does not contain that holding as cited. || Fabricated: Case Law | Plaintiff cited a nonexistent case and attributed a favorable holding; court found no such case exists and the quoted holding is fabricated. || Fabricated: Case Law | Plaintiff cited a nonexistent case to support argument about selective medical opinions; court found the citation fabricated. || Fabricated: Case Law | Plaintiff cited a nonexistent case claiming recognition of cumulative stress effects on cardiovascular health; court found the citation fabricated. || Misrepresented: Case Law | Plaintiff asserted Jones held that extended shift work contributes to cardiovascular conditions; court found Jones contains no such medical discussion (misrepresentation/paraphrase unsupported). || False Quotes: Case Law | Plaintiff attributed to Johnston a holding about considering genetic factors in medical evaluations; court found Johnston concerns confidentiality and contains no such language. || Fabricated: Case Law | Plaintiff cited a nonexistent case to argue a delay violated pension code timing; court found the citation fabricated. || Fabricated: Case Law | Plaintiff cited another nonexistent case regarding delay in issuing rulings; court found the case

Jeffery Todd Henson, Sr. v. Lynn A. Espejo

Fabricated: Case Law | Plaintiff cited a non-existent case as authority; the Court identified the citation as nonexistent and observed the reporter page corresponds to United States v. Woodrum.

BKA Holdings v. Sam

Fabricated: Case Law | A third cited authority in the reply brief was AI-generated and non-existent; the court treated the repeated reliance on fabricated cases as abusive use of AI and struck the brief. || Fabricated: Case Law | A fourth AI-generated case citation was included in the reply brief; the court noted four hallucinated cases and granted plaintiff's sanctions motion. || Fabricated: Case Law | Defendants' reply brief cited an AI-generated, non-existent case; the court found the authority hallucinated and struck the reply brief as part of granting sanctions. || Fabricated: Case Law | A second AI-generated case citation appeared in defendants' reply brief; the court identified it as hallucinated and relied on the existence of multiple fabricated cases in granting sanctions.

Nicholas George DiCristina v. The Department of Employment Security, et al.

Fabricated: Case Law | Appellant's opening brief cited cases that do not exist and included AI-generated content (repetitive 'refined' drafts and the statement 'Generative AI is experimental'); the court flagged those non-existent citations as fabricated.

Poole v. Walmart, Inc.

Outdated Advice: Repealed Law | Plaintiff cited an incomplete/unspecified Westlaw entry attributed to the (nonexistent) Eastern District of Illinois; court could not find it and treated it as a hallucinated citation. || Fabricated: Case Law | Plaintiff cited Phipps v. Sears, Roebuck & Co., which the court and defendant could not locate; court identified it as non-existent. || Fabricated: Case Law | Plaintiff cited Carberry v. Chicago Transit Authority, which the court and defendant could not locate; court identified it as non-existent. || Fabricated: Case Law | Plaintiff cited Cain v. Chicago Transit Authority, which the court and defendant could not locate; court identified it as non-existent. || Fabricated: Case Law | Plaintiff cited a Miller decision purporting to be from the Eastern District of Illinois; court noted the Eastern District of Illinois no longer exists and could not verify the citation.

Steven E. Hobbs, Sr. v. Igor Goncharko, et al.

Fabricated: Case Law | Pro se plaintiff cited 'Lathan v. Brinkerhoff' in briefing; court and defense counsel could not locate the case and called it a ghost citation.

In re R.L.

Fabricated: Case Law | Appellant cited In re C.P., 2018 IL App (4th) 180378, which the court found does not exist; court flagged this as an example of counsel citing nonexistent authority. || Fabricated: Case Law | Court found counsel repeatedly cited multiple cases that do not exist for propositions of law (basis for sanctions in other appeals).

In re S.M., a Minor

Fabricated: Case Law | Brief cited a non-existent case; court's research found no such opinion. || Fabricated: Case Law | Brief cited a non-existent case; court's research found no such opinion. || Misrepresented: Case Law | Case was cited for the best-interest standard of review, but the court noted C.N. does not state that standard and was cited only in the unfitness section. || Misrepresented: Case Law | Case was cited for best-interest factors, but the court explained D.D. addressed only parental unfitness.

Graciela Dela Torre v. Davies Life & Health, Inc., et al.

Misrepresented: Case Law | Plaintiff cited Kirkland v. American Title Ins. Co., "692 F. Supp. 153, 155 (N.D. Ill. 1988)"; court found the case was decided in the E.D.N.Y. and the opinion contains no discussion of certified mail, so the citation does not support the proposition. || Fabricated: Case Law | Plaintiff cited United States v. Balan, 2013 WL 5539296 (N.D. Ill. Oct. 7, 2013); court found the Westlaw number yields Trahan v. Verret (La. App. Ct. 2013) and no matching N.D. Ill. decision exists — citation incorrect/likely fabricated. || Misrepresented: Legal Norm | Plaintiff relied on 735 ILCS 5/2-203.1 to argue certified mail is effective service; court explained the statute only permits moving for alternative service authorization and does not itself authorize service by certified mail. || Misrepresented: Case Law | Plaintiff cited People ex rel. Devine v. $30,700.00 U.S. Currency, 199 Ill. 2d 142 (2002); court noted Devine is an Illinois forfeiture case governed by different statutes about notice of forfeiture and is inapposite to service of process. || Misrepresented: Case Law | Plaintiff cited In re Marriage of Schmitt, 391 Ill. App. 3d 1010 (2d Dist. 2009); court found Schmitt concerns dissolution of marriage and contains no discussion of service by certified mail, making the citation irrelevant. || Misrepresented: Legal Norm | Plaintiff cited 735 ILCS 5/2-203.1 as authorizing service by certified mail; the court explained the statute only allows seeking authorization for alternative service and does not authorize certified-mail service without a court order. || Misrepresented: Case Law | Plaintiff cited Kirkland v. American Title Ins. Co., '692 F. Supp. 153, 155 (N.D. Ill. 1988)' to support certified-mail service; the court found the opinion was from the Eastern District of New York and contains no discussion of certified mail, so the citation was misapplied/misrepresented. || Fabricated: Case Law | Plaintiff cited 'United States v. Balan, 2013 WL 5539296

Illinois HB 3506

Requires developers to establish, publish, and adhere to safety and security protocols and conduct regular risk assessments and third-party audits. Imposes civil penalties for violations up to $1,000,000.

Illinois SB2203

Prohibits AI system deployers in Illinois from causing algorithmic discrimination. Requires annual impact assessments and governance programs to manage AI risks.

Illinois House Bill 4875

Amends the Right of Publicity Act to regulate AI-generated digital replicas, prohibiting unauthorized commercial use without consent. Establishes liability for knowingly distributing such replicas. Exempts certain uses, like news or satire. Applies protections for 50 years posthumously. Effective January 1, 2025.

Public Act 103-0804

Prohibits employers in Illinois from using AI in employment practices that result in discrimination based on protected classes. Requires employers to notify employees when AI is used for employment decisions. Mandates rule adoption for implementation and enforcement. Effective January 1, 2026.

Illinois HB 4844 (2024), Section 90 ("Generative AI and Natural Language Processing Task Force")

Establishes the Generative AI and Natural Language Processing Task Force to recommend legislation, assess public service impacts, protect rights, and address cybersecurity challenges of generative AI. Requires a report to the Governor and General Assembly by December 31, 2024.

Illinois HB 3773: Artificial Intelligence Use in Employment Decisions

Illinois enacted House Bill 3773, amending the Illinois Human Rights Act to prohibit employers from using AI that has a disparate impact on protected classes in employment decisions without conducting and documenting a bias audit. The law requires employers to notify employees and applicants when AI is used in employment decisions and to provide information about the AI system upon request. It expanded on the earlier Illinois AI Video Interview Act by covering a broader range of AI-driven employment decisions beyond video interview analysis.