In re Boy
CA Illinois · Jul 21, 2025
- Jurisdiction
- state
- Court
- CA Illinois
- Record ID
- in-re-boy-2025-07-21
- Observed outcome
- Attorney ordered to disgorge $6,925.62 in fees and pay $1,000 in monetary sanctions; referral to the Illinois Attorney Registration and Disciplinary Commission.
- Known monetary consequence
- $7,925
Why this matter warrants attention
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.
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.
Disgorgement plus bar referral is the floor for unverified AI citations; require second-attorney verification pre-filing.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Family
- Appellate
- Monetary
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- $7,925
- Procedural posture
- 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.
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
Attorney admitted using AI to draft briefs.
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
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.