In re Boy
CA Illinois · Jul 21, 2025
What happened in this matter?
The court sanctioned an attorney for submitting eight AI-generated, nonexistent case citations and fabricated quotes in appellate briefs. The attorney was ordered to disgorge $6,925.62 in legal fees and pay $1,000 in additional monetary sanctions, with a referral to the state disciplinary commission.
- Why the court cared
- The court reasoned that the attorney violated Illinois Supreme Court Rule 341(h)(7) and Rules of Professional Conduct 1.1, 3.1, 3.3, and 8.4(c) by failing to maintain competence, making false statements to the tribunal, and engaging in conduct involving dishonesty or misrepresentation. The court emphasized that the attorney's failure to verify AI-generated output, coupled with his subsequent attempts to mislead the court during the show-cause hearing, warranted sanctions under Rule 375.
- Why it matters now
- Disgorgement plus bar referral is the floor for unverified AI citations; require second-attorney verification pre-filing.
Why this matter is tracked
Fabricated: Case Law | Nonexistent case cited in briefs; court verified no such docket or decision exists. Outcome: Attorney ordered to disgorge payment and pay monetary sanctions. Counsel was sanctioned for citing eight nonexistent cases in briefs filed on behalf of his client, in an appeal concerning the termination of parental rights. The court found that Counsel violated Illinois Supreme Court Rule 375 by submitting fictitious case citations generated by AI without verification. As a result, he was ordered to disgorge $6,925.62 received for his work on the appeal and pay an additional $1,000 in monetary sanctions. The court also directed that a copy of the opinion be sent to the Illinois Attorney Registration and Disciplinary Commission.
Disgorgement plus bar referral is the floor for unverified AI citations; require second-attorney verification pre-filing.
Record details
What the record establishes about AI use
Attorney admitted using AI to draft briefs.
Appellate review of a parental rights termination order, including a court-initiated rule to show cause regarding the attorney's use of fictitious case law.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
12 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Nonexistent case cited in briefs; court verified no such docket or decision exists.
- Fabricated: Case Law | Fabricated quote attributed to a nonexistent case; court found no Illinois, other state, or federal decision contains it.
- Fabricated: Case Law | Nonexistent case admitted by counsel after rule to show cause.
- Fabricated: Case Law | Nonexistent case admitted by counsel after rule to show cause.
- Fabricated: Case Law | Nonexistent case used to support a Faretta inquiry requirement; court noted no Illinois case imposes Faretta in parental rights cases.
- Fabricated: Case Law | Nonexistent case admitted by counsel after rule to show cause.
- Fabricated: Case Law | Nonexistent case admitted by counsel after rule to show cause.
- Fabricated: Case Law | Nonexistent case cited to support self-representation/de novo review; later 'replacement' case did not support the proposition.
Show 4 additional discrepancies
- Fabricated: Case Law | Nonexistent case cited for ineffective-assistance principles; later 'replacement' case did not support the proposition.
- Misrepresented: Case Law | Real case invoked in response as supporting self-representation/de novo review; court found it does not address those issues.
- Misrepresented: Case Law | Real case invoked in response as supporting Strickland ineffective-assistance standard; court found it does not discuss ineffective assistance.
- False Quotes: Case Law | Quote misattributed to an existing case; court confirmed the case contains no such language and does not discuss incarceration.
Questions this record answers
- What happened in In re Boy?
- The court sanctioned an attorney for submitting eight AI-generated, nonexistent case citations and fabricated quotes in appellate briefs. The attorney was ordered to disgorge $6,925.62 in legal fees and pay $1,000 in additional monetary sanctions, with a referral to the state disciplinary commission.
- Why does In re Boy matter for legal AI risk?
- Disgorgement plus bar referral is the floor for unverified AI citations; require second-attorney verification pre-filing.
- What does the public record establish about In re Boy?
- 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.
- Which source supports this In re Boy summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.