{"schema_version":"0.10.0","id":"LR-2026-0704","record_version":1,"title":"Illinois appeals court fines lawyer $15,000 over AI-generated fake citations","verification":{"human_verified":false,"method":"automated_gate","auto_verified":true,"score":59.6,"score_breakdown":{"source_authority":12.1,"independent_corroboration":20.0,"implicated_party_confirmed":0.0,"citation_integrity":14.0,"specificity":3.0,"completeness":2.56,"unhedged_language":5.0},"checks":{"schema_valid":true,"every_field_cited":true,"quotes_verbatim":true,"source_fetched":true,"distinct_incident":true,"dates_plausible":true,"sources_agree":true,"source_describes_incident":true,"severe_backed_by_source":true,"record_integrity":true,"eligible":true,"about_this_case":true},"gate_version":"gate-2026-10-18.7","cross_check_model":null,"cross_check_agreement":null,"duplicate_of":null,"verified_by":null,"verified_at":"2026-11-01","extraction_run_id":null,"evidence_level":{"level":"preliminary","reason":"Publisher not yet named · subject to change","original_document":null,"reports_total":3,"reports_independent":0,"reports_derivative":0,"developing":false,"disputed":false,"rules_version":"evidence-2026-10-29.1","computed_at":"2026-11-01","history":[{"date":"2026-11-01","from_level":null,"to_level":"preliminary","reason":"Publisher not yet named · subject to change"}]},"sources_hash":"eb819196fe63b357350b197bf554fc7826843ff665f172de076a0d28f0c536a9"},"system":{"model_name":"ChatGPT","model_version":null,"developer":"unknown","harness":null,"tools_granted":[],"permissions_scope":null,"autonomy_level":"unknown","guardrails_present":[],"deployment_context":"unknown","tier":null,"lifecycle_stage":null,"integration_type":null,"intended_use":null,"safeguard_state":null,"production_intended":null},"event":{"date_occurred":null,"date_disclosed":"2026-08-03","incident_class":"hallucination","failure_class":null,"agent_involved":null,"secondary_failure_classes":[],"trigger":"unknown","duration":null,"detection_method":"unknown","summary":"A lawyer for a Starbucks employee used ChatGPT to help draft appellate briefs in a race discrimination appeal. The Illinois Appellate Court, First District, found the briefs contained false citations, misquotations and a case that does not exist, and attributed them to AI hallucinations. The lawyer said he had cross-checked citations with LexisNexis but overlooked several errors. The court upheld the dismissal of the underlying charge on jurisdictional grounds and imposed a $15,000 sanction, a flat $1,500 per false citation. Because the lawyer kept misstating the law after opposing counsel flagged the errors and after being warned of sanctions, the court referred him to the Illinois Attorney Registration and Disciplinary Commission.","tags":[],"date_detected":null,"near_miss":null,"root_cause":null,"root_cause_detail":null,"failure_class_detail":null,"responsible_party":null,"adversarial_actor":null,"input_provenance":null,"time_to_contain":null,"operations_paused":null,"remediation":null,"precursor_events":null,"primary_risk":"RK14"},"impact":{"direct_loss_usd":null,"remediation_hours":null,"records_exposed":null,"third_parties_affected_count":null,"severity":"minor","severity_because":"minor: the sanction and referral concern one case and one lawyer; no third party's data or systems are stated as touched","harm_class":[],"affected_description":null,"protected_class_involved":null,"data_categories_exposed":[],"loss_range_usd":null,"reversibility":null,"downstream_exposure_count":null},"evidence":{"sources":[{"url":"https://alabnews.com/illinois-appeals-court-fines-lawyer-15-000-refers-him-to-disciplinary-body-over-ai-generated-fake-citations/","publisher":"ALABnews -","date":"2026-08-03","type":"press","title":"Illinois Appeals Court Fines Lawyer $15,000, Refers Him to Disciplinary Body Over AI-Generated Fake Citations - ALABnews -","archived_url":null,"attachment":"first_report"},{"url":"https://www.abajournal.com/news/article/fake-ai-created-citations-result-in-real-15000-fine-for-lawyer-in-illinois-appeals-court","publisher":"ABA Journal","date":"2026-08-04","type":"press","title":"Appeals court fines lawyer in Starbucks bias case $15K for AI-generated fake citations - ABA Journal","archived_url":null},{"url":"https://www.wansom.ai/briefly/news/illinois-appeals-court-sanctions-lawyer-15k-for-ai-generated_3ea4b679-3d87-4ec0-9c48-d592e31ee9b9","publisher":"Wansom AI","date":"2026-08-04","type":"press","title":"Illinois Appeals Court Sanctions Lawyer $15K for AI-Generated Fake Citations - Wansom AI","archived_url":null}],"per_field_confidence":{"system.model_name":"C","event.incident_class":"C","impact.severity_because":"D","impact.severity":"D","event.primary_risk":"D","event.summary":"C","system.autonomy_level":"D","system.deployment_context":"D","event.trigger":"D","event.detection_method":"D","context.country":"D","system.developer":"D","event.date_disclosed":"D","context.denominator_available":"D"},"field_citations":{"system.model_name":[{"source_index":0,"quote":"In a written response ordered by the court, Cole acknowledged the fabrications were false and said he uses a \"premier corporate subscription of ChatGPT\" to help synthesize complex legal issues."}],"event.incident_class":[{"source_index":0,"quote":"The court determined the errors were the product of AI hallucinations from a chatbot Cole said he used to help draft filings."}],"impact.severity_because":[{"source_index":1,"quote":"Lawyer Mason Cole of Cole Sadkin submitted briefs on behalf of Starbucks employee Kimberly Scott with false citations, quotes and even a fictitious case, the Illinois Appellate Court for the First District found."}],"impact.severity":[{"source_index":1,"quote":"The appeals court, which upheld a decision by the Illinois Human Rights Commission to dismiss the race discrimination charge by Scott, imposed a flat $1,500 penalty per false citation on Cole."}],"event.summary":[{"source_index":0,"quote":"The court determined the errors were the product of AI hallucinations from a chatbot Cole said he used to help draft filings."},{"source_index":0,"quote":"He said he had cross-referenced citations with LexisNexis but \"overlooked\" several errors, attributing the mistakes to his inexperience in appellate practice."},{"source_index":0,"quote":"The panel rejected that framework, instead imposing a flat $1,500 penalty per false citation, arguing there is no meaningful distinction between a fabricated quote, an invented case, and a real case misrepresented to the court."},{"source_index":0,"quote":"The court said the referral was necessary because Cole continued to misstate the law even after opposing counsel flagged the errors and after being warned that sanctions were under consideration."},{"source_index":1,"quote":"The court said it upheld the Commission’s ruling that it did not have jurisdiction over Scott’s claims because she had not submitted the EEOC’s determination in her case to the state Department of Human Rights with 30 days of receiving it, as required by law."}]},"notes_on_gaps":"No autonomous agent is described; the tool was a chatbot used by a lawyer to draft briefs, so agent_involved is false and no failure_class is given. Sources do not state the filing dates, the date of occurrence, or the detection method, so those fields are omitted; the 2026-07-28 date is the court ruling date. Developer, harness, autonomy level, and country are not stated and are omitted; the country is not given as a code because the sources name only Illinois. Responsible party 'deployer' and root cause 'oversight' are my judgement from the lawyer's use and failed verification. Severity 'minor' is my judgement: no third-party data or systems are stated as touched. No remediation by the lawyer or a provider is reported. Source 1 says it was updated Sept. 14 with the reason for dismissal but gives no year, so I did not use that date. Source 2 is an AI-generated summary and was used only for consistency with the other sources. [case created by the backfill: read by claude-haiku-5-5, backfill-2026-11-01.2, 2026-11-01; not yet reviewed] [2026-11-01: evidence level set: Preliminary (Publisher not yet named · subject to change)]"},"context":{"industry":null,"org_size_band":null,"country":"unknown","denominator_available":false,"denominator":null,"related_incident_ids":[],"systemic_exposure":null,"shared_model_id":null,"upstream_incident_id":null,"incident_evidence":null,"regulatory":null,"coverage":null},"narrative":{"steps":[{"step":"went_wrong","text":"The filed briefs contained false citations and quotations, including a nonexistent case and misquoted statutes.","quote":"The court found that attorney Mason Cole, of Cole Sadkin, LLC, filed briefs containing false citations and quotations, including a case that does not exist, misquoted statutes, and real cases that were cited for legal propositions they do not actually support.","source_index":0,"grade":"C"},{"step":"reached","text":"The false citations reached the Illinois Appellate Court, First District, in the appeal.","quote":"Lawyer Mason Cole of Cole Sadkin submitted briefs on behalf of Starbucks employee Kimberly Scott with false citations, quotes and even a fictitious case, the Illinois Appellate Court for the First District found.","source_index":1,"grade":"C"}],"model":"claude-haiku-5-5","prompt_version":"backfill-2026-11-01.2","extracted_at":"2026-11-01","source_urls":["https://alabnews.com/illinois-appeals-court-fines-lawyer-15-000-refers-him-to-disciplinary-body-over-ai-generated-fake-citations/","https://www.abajournal.com/news/article/fake-ai-created-citations-result-in-real-15000-fine-for-lawyer-in-illinois-appeals-court","https://www.wansom.ai/briefly/news/illinois-appeals-court-sanctions-lawyer-15k-for-ai-generated_3ea4b679-3d87-4ec0-9c48-d592e31ee9b9"]}}