The Seventh Circuit Fines a Lawyer Who Signed and Filed a Brief Riddled With AI Hallucinations Without Reviewing It

The United States Court of Appeals for the Seventh Circuit decided No. 25-1988 on June 1, 2026. It denied a petition for review of a removal order on the merits, and then turned to the brief that had been filed for the petitioner. The court says the case "raises a pressing concern facing the legal profession today: the use of artificial intelligence ("AI") in litigation." Parts of the opinion follow, not the whole, and the article names neither lawyer nor the petitioner.

A Brief Prepared by One Lawyer and Signed by Another

The court found the opening brief "riddled with AI hallucinations." From pages 19 to 29, it says, every quote appeared to be an AI hallucination. "All told, there were twenty-four unattributable or outright false quotes, along with at least seven mislabeled or nonexistent cases." The court also found "false or unsupported claims about the record" in the brief, among them claims about the petitioner's family. To avoid memorializing errors, the court chose not to include any of the false citations or quotes in its opinion.

By the account of the lawyer of record, another attorney had written it. That lawyer told the court the research and preparation of the brief had been outsourced to an attorney who did not enter an appearance in the case, and conceded having "had no input in the research and preparation of the brief". The lawyer of record said the other attorney had used AI "for the limited purpose of stylistic and grammatical review". That attorney, in turn, accepted responsibility for not checking the brief after using the tool.

At oral argument the lawyer of record admitted not reviewing the original brief for accuracy, or the edited one filed late the night before argument. That revised brief replaced the false citations with real cases but, the court says, "did not cure all deficiencies." The lawyer defended not reviewing the briefs by pointing at the other attorney: "I didn't believe that it was on me to redo the brief for someone who's writing briefs as an attorney."

The Sanction for the Lawyer Who Signed

The court sanctioned the lawyer of record under Federal Rule of Appellate Procedure 46, which gives a court of appeals power to discipline a member of its bar for conduct unbecoming a member of the bar. The lawyer "signed his name to a brief containing many AI hallucinations," the opinion says, and in signing certified that its representations were warranted by existing law and supported by the record. The lawyer then filed the second version without reviewing it either, after the court had put the lawyer on notice of its deficiencies. "Attorneys practicing before this court should never sign and submit a brief they have not reviewed."

The fine was $5,000 under Rule 46(c). The court did not bar the lawyer from practicing before it, noting no prior record of misconduct, but said the lawyer "is on notice that the next time any incident occurs, he could be subject to disbarment before this court."

The sanction falls on the signature. A lawyer who hands a brief to someone else to prepare still answers, under this opinion, for every line filed under that lawyer's name.

The Author, and the Questions Still Open

For the attorney who wrote the brief, the court said it had hesitated to sanction lawyers who are not admitted to its bar under Rule 46, and that it was not clear that merely writing a brief counted as practicing before it. It used its inherent authority to issue a show cause order to that attorney, and then declined to sanction "at this juncture," saying it had no evidence of fraud on the court and that nothing in the attorney's apologetic response indicated bad faith. It admonished the attorney all the same: "Attorneys must ensure that their work product does not contain false legal citations or factual errors, whether they enter an appearance in the case or not."

The court also referred the matter to the Attorney Registration and Disciplinary Commission of Illinois. "Even after conducting our own inquiry into the matter, questions remain as to how such egregious errors made their way into this brief." It called the author's factual explanations "wanting" and said, "It is unlikely that such pervasive errors would arise through a grammar check." It noted some concern, too, about whether the client consented to the contractual agreement between the two lawyers.

The show cause order stays open until the commission has had a chance to review the matter. Each lawyer must file a status report saying whether the commission has chosen to investigate, one year from the date of the decision or within seven days of any final action by the commission, whichever comes first. "Members of this court's bar must be exceedingly careful about outsourcing their work product."