Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 24, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · N.D. Illinois, USA · 2026-09-24

Adams v. Board of Trustees of the University of Illinois at Chicago et al.

What happened

In N.D. Illinois, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

False Quotes (Case Law)

The brief attributed the quotation “The IHRA is a remedial statute and must be liberally construed to protect claimants’ rights” to Thakkar. The court could not find the quotation in the case and noted that the citation was incorrect and lacked a page citation.
Misrepresented (Case Law)

The brief cited Roxana Community School District for the proposition that a party cannot be deprived of a statutory right because an agency failed to perform a mandatory ministerial act. The court explained that Roxana concerned a school board’s authority to appeal a pollution-control decision and did not discuss that proposition.
False Quotes (Case Law)

The brief attributed to Madigan the proposition that an agency’s failure to act cannot prejudice a party who complied with its obligations, including an apparent quotation marked with “emphasis added.” The court found that the purported quotation did not appear in the case and that Madigan addressed the filing date of an electronically filed document with the Illinois Commerce Commission.
Misrepresented (Case Law)

The brief cited Castaneda for the proposition that exhaustion is satisfied when a complainant has done what the statute requires and all remaining steps are the agency’s responsibility. The court found that Castaneda instead addressed whether a party must seek review before the en banc Human Rights Commission after losing before a three-member panel.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Order to Explain

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/3194/Adams_v._Board_of_Trustees_of_University_of_Illinois_at_Chicago_USA_01-01-2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).