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Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 18, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · CA Illinois (2d), USA · 2026-09-18

In re Estate of Ruth M. Gerdes

What happened

In CA Illinois (2d), 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:

  • Fabricated (Case Law)
    The brief cited a nonexistent Second District case. A real First District case with the same name existed, but the cited paragraph did not support the proposition attributed to it.
  • Fabricated (Case Law)
    The brief cited a nonexistent case and attributed to it a quotation and a proposition about docket-management discretion. The real case was U.S. Bank Nat’l Ass’n v. Eldridge, 2020 IL App (1st) 191445-U; the quotation appeared at paragraph 42, not paragraph 28, and the case did not support the additional proposition.
  • Fabricated (Case Law)
    The brief cited a nonexistent Second District case.
  • Fabricated (Case Law)
    The brief cited a nonexistent Second District case and relied on it for a factual description of an accounting proceeding that did not occur in the real Illinois Supreme Court case.
  • Fabricated (Case Law)
    The brief cited a nonexistent Second District case and attributed to it propositions concerning mental capacity, cognitive decline, and legal incapacity. The real Third District case did not support those propositions.
  • False Quotes (Case Law)
    The brief attributed a quotation concerning the fiduciary’s burden and the manifest-weight standard to Miller, but the quotation does not appear in the cited case.
  • False Quotes (Case Law)
    The brief attributed the same purported quotation concerning the fiduciary’s burden to Rybolt. The court found that Rybolt discussed the importance of facts and evidence but did not state that the fiduciary’s burden was a question of fact in the quoted terms.
  • False Quotes (Case Law)
    The brief relied on DeJarnette for a quotation about mental capacity and cognitive decline. The cited page contained no discussion of mental capacity and instead addressed presumptions in fiduciary relationships.

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 Show Cause

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/3120/In_re_Gerdes_USA_18_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).