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Scott v. Illinois Human Rights Comm’n

Court
CA Illinois
Jurisdiction
USA
Decided
2026-07-28
AI tool
ChatGPT
Outcome
Monetary Fine; Bar Referral
Monetary penalty
15000 USD

What was hallucinated

Fabricated: Legal Norm | Opening brief quoted a fabricated statutory provision claiming the Department must “conduct a full investigation,” language not in 775 ILCS 5/7A-102(D)(2). Court found this language AI-generated and false. || Fabricated: Legal Norm | Opening brief falsely quoted 56 Ill. Adm. Code 5300.530(b) with language that does not appear in that provision; court identified as fabricated. || Fabricated: Case Law | Brief cited a nonexistent appellate decision titled 'Harris v. Illinois Human Rights Comm’n, 2022 IL App (1st) 210454.' Court found the citation refers to no such case. || Misrepresented: Case Law | Counsel attributed a nonexistent "definition of arbitrary and capricious action" to Gusciara v. Lustig; court found the quoted language does not appear in that opinion. || Misrepresented: Case Law | Counsel quoted Village of Oak Lawn as defining "substantial evidence" with language not in that opinion; court determined the attribution was inaccurate. || Misrepresented: Case Law | Counsel cited Abrahamson as supporting de novo review and a "reasoned consideration" standard; court held those propositions are not found in Abrahamson as quoted. || Fabricated: Legal Norm | In his response counsel cited a nonexistent subsection reference '775 ILCS 5/7A-102(D)(2)(a)' and misattributed statutory language to wrong subsections; court found these citations incorrect and partly obsolete.

Sanction teardown · CA Illinois, USA · 2026-07-28

Scott v. Illinois Human Rights Comm’n

What happened

In CA Illinois, USA, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Legal Norm)
    Opening brief quoted a fabricated statutory provision claiming the Department must “conduct a full investigation,” language not in 775 ILCS 5/7A-102(D)(2). Court found this language AI-generated and false.
  • Fabricated (Legal Norm)
    Opening brief falsely quoted 56 Ill. Adm. Code 5300.530(b) with language that does not appear in that provision; court identified as fabricated.
  • Fabricated (Case Law)
    Brief cited a nonexistent appellate decision titled 'Harris v. Illinois Human Rights Comm’n, 2022 IL App (1st) 210454.' Court found the citation refers to no such case.
  • Misrepresented (Case Law)
    Counsel attributed a nonexistent "definition of arbitrary and capricious action" to Gusciara v. Lustig; court found the quoted language does not appear in that opinion.
  • Misrepresented (Case Law)
    Counsel quoted Village of Oak Lawn as defining "substantial evidence" with language not in that opinion; court determined the attribution was inaccurate.
  • Misrepresented (Case Law)
    Counsel cited Abrahamson as supporting de novo review and a "reasoned consideration" standard; court held those propositions are not found in Abrahamson as quoted.
  • Fabricated (Legal Norm)
    In his response counsel cited a nonexistent subsection reference '775 ILCS 5/7A-102(D)(2)(a)' and misattributed statutory language to wrong subsections; court found these citations incorrect and partly obsolete.

Which AI tool

ChatGPT. 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

Monetary Fine; Bar Referral (monetary penalty: 15000 USD.)

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://reason.com/volokh/2026/07/31/we-do-not-know-why-attorney-cole-feels-compelled-to-rush-out-obviously-flawed-filings-but-this-must-stop-15k-sanction/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://reason.com/volokh/2026/07/31/we-do-not-know-why-attorney-cole-feels-compelled-to-rush-out-obviously-flawed-filings-but-this-must-stop-15k-sanction/

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