Illinois Department of Healthcare and Family Services ex rel. Shona L. Williams v. Samuel R. Lee, II
Illinois Appellate Court, Third District · Aug 31, 2026
- Jurisdiction
- state
- Court
- Illinois Appellate Court, Third District
- Record ID
- illinois-department-of-healthcare-and-family-services-ex-rel-shona-l-williams-v-samuel-r-l-2026-08-31
- Observed outcome
- The court identified the cited case as nonexistent but declined to dismiss the appeal or strike the brief; it reached the merits. The dissent would have stricken the brief and dismissed the appeal.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
Fabricated: Case Law | The court found that the sole authority cited in the brief, In re Marriage of Whittaker, did not exist and appeared to be fabricated or hallucinated through generative AI. The court noted that this violated the supreme court’s AI policy and could support sanctions, but it declined to dismiss the appeal or strike the brief. Outcome: The court identified the cited case as nonexistent but declined to dismiss the appeal or strike the brief; it reached the merits. The dissent would have stricken the brief and dismissed the appeal.. Samuel Lee’s brief relied exclusively on In re Marriage of Whittaker, 2021 IL App (5th) 200162-U, to argue that vacation and holiday overnights should be included in calculating child support. The appellate court determined that Whittaker was nonexistent and stated that it appeared to have been fabricated or generated through improper use of generative AI. Although the conduct was potentially sanctionable under Illinois Supreme Court Rule 375(a) and the Illinois Supreme Court Policy on AI, the majority exercised its discretion to reach the merits and remanded for recalculation of overnights. The dissent would have imposed the procedural consequence of striking the brief and dismissing the appeal.
The structured public record identifies pro se and fake citations and records The court identified the cited case as nonexistent but declined to dismiss the appeal or strike the brief; it reached the merits. The dissent would have stricken the brief and dismissed the appeal.. The linked source controls the precise reasoning and procedural context.
This matter connects pro se and fake citations with The court identified the cited case as nonexistent but declined to dismiss the appeal or strike the brief; it reached the merits. The dissent would have stricken the brief and dismissed the appeal. in Illinois Appellate Court, Third District. It provides a source-linked baseline for verification, supervision, and response controls.
Failure modes and consequences
- Pro Se
- Fake Citations
- Trial
- Struck Filing
- Case Dismissed
- AI attribution
- Reported
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The court identified the cited case as nonexistent but declined to dismiss the appeal or strike the brief; it reached the merits. The dissent would have stricken the brief and dismissed the appeal.
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
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
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.
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Read the linked source and subsequent docket history before relying on this record for legal work.