By Bill Hartzer · Published · How this site is researched
What happened
The plaintiff, representing herself, sued Cook County, Illinois, several lawyers and law firms, and state court judges. The court dismissed the complaint on November 18, 2025. She then moved to alter or amend the judgment and filed reply briefs.
The court had already encountered the problem. According to the April 9, 2026 order, an earlier brief in the case contained at least 17 fabricated cases, quotations or statements, and the court extended leniency at that time. The post-judgment filings contained at least 13 more. They included a citation to "Andrade v. Arby Concessions, 88 F.4th 1014," which does not exist, a misquotation of the Supreme Court's decision in Marshall v. Marshall, and language attributed to the court's own earlier orders that those orders do not contain.
The court found that the plaintiff "generated each brief using AI." The order does not name the tool.
What the court did
Chief Judge Virginia M. Kendall struck the motion and reply briefs for exceeding the 15-page limit of Local Rule 7.1 without leave. She separately imposed a monetary sanction under Rule 11 of the Federal Rules of Civil Procedure, which requires that a signer's legal contentions be warranted by existing law. The order states: "The Court sanctions Plaintiff $5,000 for filing false cases, quotes, and statements of law and fact to the Court in violation of Rule 11." Payment was due to the Clerk of the Court within 2 weeks.
The court explained the harm in practical terms: "This wastes both the parties' and the Court's time attempting to locate nonexistent cases and unpack made up factual assertions." In setting the amount, the order surveyed other decisions that imposed sanctions from $1,500 to $10,000 for hallucinated citations. It did not add a filing restriction.
On self-representation the order states: "Pro se status does not shelter plaintiffs from sanctions pursuant to Rule 11." Eugene Volokh's summary of the order describes the fabrications as "egregious, repeated, and ongoing."
Where it stands
The underlying case had been dismissed before the sanctions order. Whether the plaintiff paid the sanction or appealed was not confirmed as of September 11, 2026.
The obligation it engaged
The Expert Record Standard is written for professionals, but its Clause 3 (independent authority) describes the same duty Rule 11 places on every signer. A self-represented party who files a brief drafted by a system adopts every citation in it. Here the court's own orders were misquoted back to it, which is the most checkable source a litigant has.
The earlier warning matters to the record. The court extended leniency after the first set of fabrications and imposed a monetary sanction when they recurred. For a professional reading this record, the point is that the verification duty does not scale with training or resources. It attaches to the signature.
Sources
- U.S. District Court, N.D. Ill. (via CourtListener) · April 9, 2026
Obi v. Cook County, Illinois, No. 1:25-cv-03096, Order, ECF No. 97 - Reason (The Volokh Conspiracy) · April 16, 2026
$5K Sanctions for "Egregious, Repeated, and Ongoing" AI Hallucinations in Self-Represented Litigant's Filings
What could not be confirmed
Payment of the sanction and any appeal were not confirmed. The tool used was not identified in the order.
About this entry
This entry was checked against the primary document listed in the sources. The entry for Obi v. Cook County records conduct and what the tribunal did. It does not characterize a holding and it is not legal advice. Last checked September 11, 2026. More matters like this one are collected under hallucinated citations and facts. If something here is out of date, write to [email protected].