The District Court for the Northern District of Illinois has imposed rule 11 sanctions in the amount of $9750 on a pro se litigant. The court noted that there were repeated uses of hallucinated cases. Chinedu Obi v. Cook County, Illinois, No. 25-c-3096 (Kendall, J.)
“Normally the Court, recognizing Plaintiff’s pro se status, would offer leeway and consider Plaintiff’s briefs despite violating Local Rule 7.1. Plaintiff’s egregious, repeated, and ongoing Rule 11 violations, however, foreclose any such possibility. Plaintiff generated each brief using AI. Plaintiff’s motion is riddled with AI hallucinations, made up cases, quotes, and statements of law and fact. (Dkt. 90); (see also Dkt. 92-1) (identifying 13 hallucinated cases, quotes, and statements of law). For example, Plaintiff quotes Marshall v. Marshall, 547 U.S. 293 (2006) for the rule that “Federal courts may exercise jurisdiction even when the case touches upon matters traditionally reserved to state law, where federal rights are at issue.” (Dkt. 90 at 3). That quoted language is not in Marshall. Plaintiff cites Andrade v. Arby Concessions, 88 F.4th 1014, 1018 (7th Cir. 2023) to dispute the Court’s Order dismissing her complaint. (Dkt. 90 at 6). “Andrade” is not a real case. Plaintiff’s reliance on AI hallucinations is not limited to made up cases either….
The severity of Plaintiff’s Rule 11 ongoing and repeated violations warrants sanctions. “Pro se status does not shelter plaintiffs from sanctions pursuant to Rule 11.” Helen Allen v. Cass Casper & Disparti Law Group, 2026 WL 674309, at *9 (N.D. Ill. Mar. 10, 2026) (quoting Eberhardt v. Vill. of Tinley Park, 2022 WL 22896754, at *2 (N.D. Ill. Aug. 18, 2022)); Vukadinovich v. McCarthy, 901 F.2d 1439, 1445 (7th Cir. 1990). “When a self-represented party files a document in federal court, that party is certifying to the court that the legal contentions contained in it `are warranted by existing law.'” Id. (quoting Fed. R. Civ. P. 11(b)(2)). “`Carelessness, good faith, or ignorance are not an excuse for submitting materials that do not comply with Rule 11.'” Id. (quoting Attaway v. Illinois Dep’t of Corr., 2025 WL 1101398, at *2 (S.D. Ill. Apr. 14, 2025)). Plaintiff “must ensure that the case citations and representations she presents to the court are accurate and are supported by valid precedent; the fact that she is representing herself does not relieve her of that duty.” Id.”
“Filing a document that contains citations to nonexistent cases, quotes language that comes from no real case, or that contains arguments wholly unsupported by the record violates Rule 11.” Id. at *10. Plaintiff did just that repeatedly. “This demonstrates that [Plaintiff] failed to make a reasonable inquiry into the supporting law or facts. This wastes both the parties’ and the Court’s time attempting to locate nonexistent cases and unpack made up factual assertions.” Id. The Court sanctions Plaintiff $9,750 for filing false cases, quotes, and statements of law and fact to the Court in violation of Rule 11. Id. (sanctioning plaintiff $1,500 for filing at least two false cases and statements of law); Seth Cameron Virgil v. Experian Information Solutions Inc, et al., 2026 WL 401066, at *5 (S.D. Ind. Feb. 12, 2026) (recommending $10,000 sanction for submitting a brief with hallucinated cases); Mid Cent. Operating Eng’rs Health & Welfare Fund v. HoosierVac LLC, 2025 WL 1511211 (S.D. Ind. May 28, 2025) (imposing $6,000 sanctions for briefs containing hallucinated citations); Davis v. Marion Cnty. Superior Ct. Juv. Det. Ctr., 2025 WL 2502308 (S.D. Ind. Sept. 2, 2025) (recommending $7,500 sanction for a brief containing hallucinated citations).”
Comment: courts are becoming increasingly frustrated by the use of AI in legal briefs.