D'Angelo v. Vaught
CC Illinois · Apr 2, 2025
- Jurisdiction
- state
- Court
- CC Illinois
- Record ID
- dangelo-v-vaught-2025-04-02
- Observed outcome
- The court ordered attorney Scott Walker to pay a $2,000 sanction ($1,000 per citation) to the Lawyers Assistance Program.
- Known monetary consequence
- $2,000
Why this matter warrants attention
The court imposed a $2,000 monetary sanction against attorney Scott Walker for twice citing a non-existent case in court filings. The attorney attributed the error to the use of Smokeball's AI tool, Archie, which he claimed inadvertently altered or replaced his intended citations during the document editing process.
The court reasoned that under Illinois Supreme Court Rule 137, an attorney's signature certifies that a filing is well-grounded in fact and law. The court determined that the attorney's failure to verify the existence of cited cases, whether due to negligence or reliance on AI, warranted a sanction to deter future frivolous filings and uphold the integrity of the court's proceedings.
Vendor-branded legal AI tools like Smokeball's Archie still hallucinate; treat every output as unverified until cite-checked.
Failure modes and consequences
- Trial
- Monetary
- AI attribution
- Admitted
- Recorded tool
- Archie (Smokeball)
- Known monetary consequence
- $2,000
- Procedural posture
- The court initiated sanctions proceedings on its own motion following the discovery of fabricated case citations in filings dated October 18, 2024, and January 3, 2025.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The attorney admitted in an affidavit to using Archie, an AI developed by Smokeball.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory manual verification for all case citations generated or edited by AI tools.
- Establish a firm-wide policy requiring attorneys to review and sign off on the accuracy of AI-assisted drafts before filing.
- Maintain documentation of the specific AI tools used in the drafting process to ensure compliance with court disclosure requirements.