Morgan Cole v. Hobby Town Unlimited, Inc.
C.D. Illinois · Sep 2, 2026
What happened in this matter?
Fabricated: Case Law | The default-judgment motion contained four hallucinated citations, including citations to non-existent cases or authorities that were inaccurately described; the Court treated them as classic indicators of unverified AI use and found their inclusion objectively unreasonable under Rule 11. Outcome: Attorney David Baldemar Reyes was ordered to pay a $1,000 Rule 11 sanction and send the order to the Illinois ARDC.. Attorney Reyes admitted that a motion for default judgment contained four inaccurate, AI-generated citations and accepted responsibility for failing to independently verify them. The Court found that the motion included non-existent or mischaracterized cases, and that the same or similar hallucinations had appeared in at least two prior filings, including filings in Hippe and Pittman. Because prior corrective measures had failed, the Court imposed a $1,000 Rule 11 sanction for deterrence and required Reyes to send the order to the Illinois ARDC.
- Why the court cared
- The structured public record identifies fake citations and misrepresented authority and records Attorney David Baldemar Reyes was ordered to pay a $1,000 Rule 11 sanction and send the order to the Illinois ARDC.. The linked source controls the precise reasoning and procedural context.
- Why it matters now
- This matter connects fake citations and misrepresented authority with Attorney David Baldemar Reyes was ordered to pay a $1,000 Rule 11 sanction and send the order to the Illinois ARDC. in C.D. Illinois. It provides a source-linked baseline for verification, supervision, and response controls.
Why this matter is tracked
Fabricated: Case Law | The default-judgment motion contained four hallucinated citations, including citations to non-existent cases or authorities that were inaccurately described; the Court treated them as classic indicators of unverified AI use and found their inclusion objectively unreasonable under Rule 11. Outcome: Attorney David Baldemar Reyes was ordered to pay a $1,000 Rule 11 sanction and send the order to the Illinois ARDC.. Attorney Reyes admitted that a motion for default judgment contained four inaccurate, AI-generated citations and accepted responsibility for failing to independently verify them. The Court found that the motion included non-existent or mischaracterized cases, and that the same or similar hallucinations had appeared in at least two prior filings, including filings in Hippe and Pittman. Because prior corrective measures had failed, the Court imposed a $1,000 Rule 11 sanction for deterrence and required Reyes to send the order to the Illinois ARDC.
This matter connects fake citations and misrepresented authority with Attorney David Baldemar Reyes was ordered to pay a $1,000 Rule 11 sanction and send the order to the Illinois ARDC. in C.D. Illinois. It provides a source-linked baseline for verification, supervision, and response controls.
Record details
What the record establishes about AI use
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Monetary Sanction; Bar Referral
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Citations in paragraphs 18–19 could not be located on Lexis or Westlaw and were treated as fabricated by the Court.
- Misrepresented: Case Law | Plaintiff cited Liebhart v. SPX Corp., 998 F.3d 772 (7th Cir. 2021) for a four-factor injunction test that the Court found the motion misstates.
- Misrepresented: Case Law | Plaintiff cited Goodman v. Illinois Dep't of Financial & Professional Regulation, 430 F.3d 432 (7th Cir. 2005) as authority that the ADA does not provide compensatory or punitive damages, but Goodman concerns a First Amendment challenge and does not address the ADA.
- Misrepresented: Case Law | Plaintiff cited Sierra Club v. Franklin County Power of Illinois, LLC, 546 F.3d 918 (7th Cir. 2008) to support that required fixes are modest in cost, but Sierra Club addresses environmental injunctive relief and is unrelated to website accessibility costs.
Questions this record answers
- What happened in Morgan Cole v. Hobby Town Unlimited, Inc.?
- Fabricated: Case Law | The default-judgment motion contained four hallucinated citations, including citations to non-existent cases or authorities that were inaccurately described; the Court treated them as classic indicators of unverified AI use and found their inclusion objectively unreasonable under Rule 11. Outcome: Attorney David Baldemar Reyes was ordered to pay a $1,000 Rule 11 sanction and send the order to the Illinois ARDC.. Attorney Reyes admitted that a motion for default judgment contained four inaccurate, AI-generated citations and accepted responsibility for failing to independently verify them. The Court found that the motion included non-existent or mischaracterized cases, and that the same or similar hallucinations had appeared in at least two prior filings, including filings in Hippe and Pittman. Because prior corrective measures had failed, the Court imposed a $1,000 Rule 11 sanction for deterrence and required Reyes to send the order to the Illinois ARDC.
- Why does Morgan Cole v. Hobby Town Unlimited, Inc. matter for legal AI risk?
- This matter connects fake citations and misrepresented authority with Attorney David Baldemar Reyes was ordered to pay a $1,000 Rule 11 sanction and send the order to the Illinois ARDC. in C.D. Illinois. It provides a source-linked baseline for verification, supervision, and response controls.
- What does the public record establish about Morgan Cole v. Hobby Town Unlimited, Inc.?
- 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 Morgan Cole v. Hobby Town Unlimited, Inc. 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.