P-Three Development, LLC v. Therm Flo, Inc.
CA Illinois · Jun 30, 2026
- Jurisdiction
- state
- Court
- CA Illinois
- Record ID
- p-three-development-llc-v-therm-flo-inc-2026-06-30
- Observed outcome
- The appellate court struck the litigant's brief.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court struck the pro se litigant's appellate brief after determining it contained multiple fabricated cases, misrepresented legal authorities, and false quotations. The court concluded that these errors, which mirrored patterns of AI-generated hallucinations, violated procedural rules and constituted an abuse of the adversary system.
The court reasoned that the litigant's brief failed to comply with Rule 341 due to the inclusion of fictitious cases and misquoted authorities. It determined that the errors were too egregious to overlook, noting that the litigant's conduct wasted judicial resources and undermined the adversary system.
This case illustrates the judicial response to pro se litigants using AI-generated content that includes fabricated citations. It reinforces the requirement that all filers, regardless of representation status, must verify the accuracy of their legal research and citations.
Failure modes and consequences
- Pro Se
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Bar Referral
- Published Opinion
- AI attribution
- Implied
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a trial court's denial of a request for intervention.
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 court inferred the use of generative AI based on the nature of the errors.
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.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.