Illinois

Court - Judge Name

Effective Date

 Applicable To Categories

Summary

Ill. App. 2d Dist. – Judge Susan F. Hutchinson   11/24/2025   Generative AI  Generative AI Usage  In Pletcher v. Vill. of Libertyville Police Pension Bd., No. 2-24-0416, 2025 Ill. App. Unpub. LEXIS 2115 (Nov. 24, 2025), the court granted defendant’s motion for sanctions against the pro se plaintiff pursuant to Illinois Supreme Court Rule 375(a). Specifically, the plaintiff filed a complaint for an administrative review of the Village of Libertyville Pension Board’s decision on plaintiff’s application for disability pension and a supporting brief. The court found that the plaintiff’s brief cited to multiple cases that do not exist, and also cited to “actual cases” but with “fictitious quotes and holdings.” The court concluded that these fictitious citations were “hallucinated by [GenAI]” and that the plaintiff violated Rule 341(h)(7). As a result, the court sanctioned the plaintiff by striking plaintiff’s brief and dismissing his appeal.
 
Applies to AI Used for Research
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Parties
 N.D. Ill. – Judge Sharon Johnson Coleman  9/10/2025  Generative AI  Generative AI Usage  In Shanmugavelandy v. AbbVie, Inc., 2025 U.S. Dist. LEXIS 176660 (N.D. Ill. Sept. 10, 2025), the pro se plaintiff filed a motion for post-judgment relief that, according to the court, contained case law that contradicted his claims. Without saying more, Judge Coleman presumed that the plaintiff “continues to utilize artificial intelligence in his briefs, despite being admonished by the Court, on multiple times,” as GenAI use is impermissible under the Court’s standing order. No sanctions were imposed, but the court ultimately denied the motion on other grounds.
Suggests Cautious Use of AI
Applies to AI Used for Filings/Drafting
 Ill. App. Ct. – Judge Robert J. Steigmann  8/20/2025  Generative AI Generative AI Usage  In In re R.L., 2025 Ill. App Unpub. LEXIS 1474, (Ill. App. Ct. Aug. 20, 2025), the court became aware that appellant’s attorney had previously been sanctioned for citing “nonexistent cases” and “cases that do not stand for the propositions of law asserted” in two separate cases. The court found similar misconduct in this case, but decided not to pursue sanctions because the attorney had already been referred to the Attorney Registration and Disciplinary Commission and is surrendering his license for his prior misconduct.
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Attorneys/Law Firms
 Ill. App. Ct. – Judge Dwayne A. Gab 8/4/2025  Generative AI   Generative AI Usage  In In re A.S., 2025 Ill. App. Unpub. LEXIS 1371 (Ill. App. Ct. Aug. 4, 2025), counsel for the respondent included hallucinated cases in his briefing in support of a consolidated appeal. In fact, this attorney was sanctioned nearly two months prior for including “questionable citations” in a brief. Though the attorney insisted that the allegedly hallucinated citations were accurate, his response to an order to show cause made clear that the cases were cited for incorrect propositions. Additionally, though the attorney did not admit to using GenAI to assist with the briefing, Judge Gab concluded that a GenAI tool may likely have been used given the attorney’s prior behavior and that the attorney “violated Rule 375 by willfully citing multiple cases” that do not stand for their stated propositions. The court ultimately imposed a $1,000 fine on the attorney and ordered the clerk of the Fourth District Appellate Court to send a copy of this decision to the Attorney Registration & Disciplinary Commission of the Supreme Court of Illinois.
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Attorneys/Law Firms
 Bankr. N.D. Ill. – Judge Michael B. Slade  7/18/2025  Generative AI Generative AI Usage  In In re Martin, 2025 Bankr. LEXIS 1719 (Bankr. N.D. Ill. July 18, 2025), counsel for the debtor was ordered to show cause as to why they should not be sanctioned for using GenAI to draft certain briefing. During the hearing on the order to show cause, the lead attorney admitted that he did not review the AI-generated citations, as he did not see anything “wrong” with them. Further, he claimed he was unaware that GenAI could perform research and, to that extent, “result in citations to fake cases.” But his law firm testified that the lead attorney’s use of GenAI tools was in direct violation of firm policy banning the use of AI for legal research or the “generation of legal citations without manual verification.” As such, Judge Slade ordered counsel to pay a $5,500 fine and attend a course on the “dangers of AI” held by the National Conference of Bankruptcy Judges. Judge Slade suggested that attorneys like lead counsel cannot claim willful blindness regarding the use of AI and noted that his opinion will “announce loudly and clearly . . . that lawyers blindly relying on generative AI and citing fake cases are violating Bankruptcy Rule 9011 and will be sanctioned.” Additionally, given the complexity of Chapter 13 bankruptcy cases, the court expected counsel to be “more diligent and careful than has been shown here.”
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Attorneys/Law Firms
 N.D. Ill. – Judge Sharon Johnson Coleman  6/2/2025  Any AI  Any AI  In Shanmugavelandy v. AbbVie, Inc., 2025 U.S. Dist. LEXIS 104041 (N.D. Ill. June 2, 2025), the pro se plaintiff admitted to using artificial intelligence to draft his pleadings during oral argument on the parties’ motions for summary judgment in violation of Judge Coleman’s standing order prohibiting the use of any AI in filings. Although the court appreciated the plaintiff being forthcoming, Judge Coleman emphasized that “the Court cannot turn a blind eye” to inaccurate assertions and took the plaintiff’s use of AI into consideration in dismissing the action.
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Parties
 N.D. Ill. – Judge Lindsay C. Jenkins 5/6/2025  Generative AI Generative AI Usage In Qamar v. Bd. Of Trs. Of Governors State Univ., 2025 WL 1309843 (N.D. Ill. May 6, 2025), the court addressed a pro se plaintiff’s use of fabricated legal citations various filings. The court noted that the plaintiff cited a case which “neither defense counsel nor the Court has been able to locate,” raising concerns that the citation was not merely a typographical error but was instead a reference to “a non-existent case.” Although the court did not directly reference AI, it explicitly reminded the plaintiff that “[Rule 11] applies to pro se litigants” and warned that “sanctions may result” from references to fictitious cases. While the court did not impose sanctions at this stage, it cautioned that future similar conduct could result in penalties. 
Suggests Cautious Use of AI
 Applies to AI Used for Filings/Drafting
N.D. Ill. – Magistrate Judge Maria Valdez   3/7/2025 Generative AI  Generative AI Usage  In NextPulse LLC v. Life Fitness, LLC, No. 1:22-cv-03239, Dkt. No. 180 (Mar. 7, 2025), Magistrate Judge Valdez recommended to the district court that plaintiff’s counsel be sanctioned $5,000 for using fictitious, Gen AI-created citations in her response to the defendant’s motion to compel further responses to interrogatories. According to plaintiff’s counsel, the citations included in the briefing arose from her decision to show her daughter a non-final version of the brief, to insert fake “case quotes and citations” from ChatGPT into the brief which “look[] real [but] [] are fake” in order to educate her daughter of the dangers of misusing Gen AI, and to then submit a non-final version of that brief to the court. Expressing substantial doubt as to the explanation (describing it as a “tale” which “beggars belief” and demonstrates a “general lack of candor,” including because the false citations formed “the entirety of her argument” on a particular legal issue), Judge Valdez concluded that imposing $5,000 in sanctions would be adequate to “punish [counsel] for her dishonesty and deter future misconduct by her and others.” 
Requires Disclosure and/or Verification
Suggests Cautious Use of AI
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Attorneys/Law Firms
Cook County Circuit Court – Judge Horan    4/5/2024 Generative AI  Generative AI Usage The order requires all attorneys appearing before the Court to indicate in the caption of any filing if the attorney prepared the filing using large language model artificial intelligence. The order specifically names ChatGPT as an example of a large language model artificial intelligence. The order explicitly states that failure to include the disclosure may result in sanctions for the attorney.
Requires Disclosure and/or Verification
Applies to AI Used for Filings/Drafting
 N. D. Illinois – Judge Coleman  4/3/2024 Any AI   Any AI Usage  Judge Coleman has a standing order listed on the court’s website titled “Memorandum of Law Requirements” in which she prohibits any use of AI to draft memoranda or “as authority to support” a motion. This language uniquely forbids AI itself from being cited as a source, rather than the more typical practice found in other court orders which address citations created by AI. The order also does not refer to gen AI specifically and applies to any AI.
Prohibits Use of AI
Applies to AI Used for Research
Applies to AI Used for Filings/Drafting
N.D. Ill. - Magistrate Judge Gabriel A. Fuentes 4/2/2024  Generative AI Generative AI Usage This standing order primarily focuses on the use of any “generative AI tool" in the preparation or drafting of documents for filing with the Court and requires disclosure of any filing in which generative AI was used to conduct legal research and/or to draft the document.  The order has been revised from its original form, and no longer requires disclosure of which generative AI tools were used or how they were used, while also emphasizing that the order is “not intended” to “discourage use of generative AI” or to “trigger greater judicial scrutiny” of briefs containing such disclosures.
Requires Disclosure and/or Verification
Applies to AI Used for Research
Applies to AI Used for Filings/Drafting 
Cook County Circuit Court – Judge Cleary    2/13/2024 Any AI    Any AI Usage  The standing order requires disclosure if a party has used any AI in the “creation” of a filing. That disclosure must be part of the same document. In such cases, the party must also verify the existence and accuracy of any authority cited. The order does not distinguish between gen AI or other forms of AI, so it is applicable to all AI usage. There are no carveouts or exceptions for AI-powered research tools.
 Requires Disclosure and/or Verification
Applies to AI Used for Filings/Drafting
Illinois Human Rights Commission – Judge Weinthal   8/1/2023 Generative AI  Generative AI Usage The standing order cautions parties against using gen AI to compose legal pleadings. The order specifically calls out gen AI products ChatGPT, Harvey.AI, and Google Bard, emphasizing that the platforms “do not provide the necessary guarantees of accuracy and reliability that are required for legal writing.” Lastly, the order reminds parties that they will be responsible for the accuracy of their pleadings and makes clear that use of gen AI will not provide a legal defense to allegations that information provided by such a tool was misleading or untrue. However, this order does not prohibit or restrict the use of Gen AI. 
Suggests Cautious Use of AI
Applies to AI Used for Filings/Drafting
N.D. Ill. – Judge Iain D. Johnston  12/19/2023  Any AI   Any AI Usage This standing order applies to AI generally, and reminds both lawyers and pro se litigants to comply with Federal Rules of Civil Procedure 11(b) and 26(g), and any other relevant rules, when using AI “in connection with the filing of a pleading, motion, or paper in this Court or the serving/delivering of a request, response, or objection to discovery.”  There are no prohibitions, disclosure requirements, or other limitations on the use of AI.
Suggests Cautious Use of AI
Applies to AI Used for Research
Applies to AI Used for Filings/Drafting
N.D. Ill. - Magistrate Judge Jeffrey Cole   7/21/2023  Any AI Any AI Usage  This standing order refers generally to “artificial intelligence” and “AI,” requiring disclosure of the use of any “AI tool” for “research and/or drafting.” The order appears to imply that this disclosure should be in the form of a certification, as it says that “a certification on a filing will be deemed as a representation” that the filer has verified all cited legal authorities in a given document.
Requires Disclosure and/or Verification 
Applies to AI Used for Research
Applies to AI Used for Filings/Drafting