# An Illinois appeals court fined attorney Mason Cole $15,000 for ChatGPT-hallucinated citations

> In Scott v. Illinois Human Rights Comm'n (2026 IL App (1st) 251462, July 28 2026), the Appellate Court of Illinois, First District fined petitioner's attorney Mason Cole $15,000 - $1,500 for each of 10 false citations that were the product of AI (ChatGPT) hallucinations - and referred him to the ARDC.

- Verification status: verified
- Case type: deployment
- Provider: Appellate Court of Illinois, First District (Second Division)
- Client: Scott v. Illinois Human Rights Comm'n (attorney Mason Cole sanctioned), Legal / judiciary (named)
- Sector: legal / US / cross
- Verified on: 2026-08-27
- Canonical URL: https://theinternetninja.com/stories/scott-v-illinois-hrc-ill-app-1st-van-tine-cole-15000-chatgpt-fabricated-citations-rule-375-2026/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Outcomes

| Metric | Before | After |
| --- | --- | --- |
| Monetary sanction on attorney Cole |  |  |
| Rate per false citation/quotation |  |  |
| Disciplinary referral |  |  |

## Verification method

Primary: published opinion 2026 IL App (1st) 251462 (byte-tied: local PDF sha1 == CourtListener published sha1 7599d20b...). Two independent newsrooms (ABA Journal, Human Resources Director/hcamag, and Reason/Volokh) carry the $15,000 firsthand.

## FAQ

**How much was attorney Mason Cole fined for the ChatGPT citations?**

The Appellate Court of Illinois, First District, fined him $15,000, at $1,500 for each of 10 false citations (4 false statutory quotations, 1 nonexistent case, and 5 cases that do not contain the cited principle), under Rule 375(a) and 375(b), and referred him to the ARDC.

**What AI did the attorney admit using in Scott v. Illinois Human Rights Comm'n?**

Attorney Cole admitted he 'frequently use[s] a premier corporate subscription of ChatGPT' to synthesize complex matters, including this case. The court held the AI provenance did not mitigate the false citations.

## Full case file

## What happened

Kimberly Scott, an African American woman who worked at a downtown Chicago Starbucks, brought a workplace-racial-discrimination charge that the Illinois Department of Human Rights dismissed and the Illinois Human Rights Commission sustained; her attorney, Mason Cole of Cole Sadkin, appealed to the Appellate Court of Illinois, First District [source](https://www.courtlistener.com/opinion/10935788/scott-v-illinois-human-rights-commn/). On July 28, 2026, in a published opinion (2026 IL App (1st) 251462, No. 1-25-1462) by Presiding Justice Rena Van Tine, with Justices David Ellis and Debra B. Walker concurring, the court affirmed the dismissal of Scott's charge and sanctioned her attorney [source](https://www.courtlistener.com/opinion/10935788/scott-v-illinois-human-rights-commn/). The court's own words: "We also sanction petitioner's attorney Mason Cole for submitting briefs containing false citations and quotations that are the product of artificial intelligence (AI) hallucinations" [source](https://www.courtlistener.com/opinion/10935788/scott-v-illinois-human-rights-commn/).

## The AI use

Cole drafted his filings with generative AI, and the opinion records his own admission: "Attorney Cole states that he 'frequently use[s] a premier corporate subscription of ChatGPT' to 'synthesize complex matters,' including this case" [source](https://www.courtlistener.com/opinion/10935788/scott-v-illinois-human-rights-commn/). An independent trade newsroom reported the same concession: "The lawyer conceded he used 'a premier corporate subscription of ChatGPT' to draft filings" [source](https://www.hcamag.com/us/specialization/employment-law/court-fines-lawyer-15000-over-ai-citations-in-starbucks-bias-case/584304). The court held the AI provenance is no excuse: it imposed the sanction "pursuant to Rule 375(a) and 375(b), both of which authorize monetary fines," reasoning that the attorney, not the tool, retains ultimate responsibility for what is filed [source](https://www.courtlistener.com/opinion/10935788/scott-v-illinois-human-rights-commn/).

## The sanction

The court itemized the falsehoods: "Attorney Cole's briefs contain a total of 10 false citations: 4 false statutory quotations, 1 nonexistent case, and 5 cases that exist but do not contain the cited principle or quoted language. This sanction reflects a $1,500 fine for each false citation and quotation" [source](https://www.courtlistener.com/opinion/10935788/scott-v-illinois-human-rights-commn/). It ordered "attorney Cole to pay a $15,000 fine to the clerk of the Appellate Court, First District, within 30 days of this opinion" [source](https://www.courtlistener.com/opinion/10935788/scott-v-illinois-human-rights-commn/). Three independent newsrooms carry the figure firsthand: the ABA Journal reported the court "fined an attorney $15,000 in an effort to crack down on and deter the misuse of artificial intelligence in case briefs" [source](https://www.abajournal.com/news/article/illinois-appeals-court-imposes-higher-sanction-on-attorney-to-deter-unacceptable-misuse-of-ai); Human Resources Director wrote it "ordered him to pay $15,000 - $1,500 for each of 10 false citations" [source](https://www.hcamag.com/us/specialization/employment-law/court-fines-lawyer-15000-over-ai-citations-in-starbucks-bias-case/584304); and Reason's Volokh Conspiracy noted "The court sanctioned Cole $15,000" [source](https://reason.com/volokh/2026/07/31/we-do-not-know-why-attorney-cole-feels-compelled-to-rush-out-obviously-flawed-filings-but-this-must-stop-15k-sanction/). Beyond the fine, the court directed that "the clerk of the Appellate Court, First District, shall send a copy of this opinion to the ARDC", the Illinois Attorney Registration and Disciplinary Commission [source](https://www.courtlistener.com/opinion/10935788/scott-v-illinois-human-rights-commn/), a referral Human Resources Director also reported [source](https://www.hcamag.com/us/specialization/employment-law/court-fines-lawyer-15000-over-ai-citations-in-starbucks-bias-case/584304).

**A note on the weakest link:** the strongest anchor here is the published opinion itself (Tier 1), but it has no organic web.archive.org snapshot (anonymous archiving of illinoiscourts.gov is login-gated from our host), so its archival proof is a SHA-1 byte-match to CourtListener's rehosted PDF rather than an independent Wayback capture. The ABA Journal page (Tier 2) likewise could not be Wayback-archived (a bot-block returned 403) and is preserved only as a saved live-HTML copy; the $15,000 figure does not depend on it, since the primary opinion plus two byte-tied independent captures (Reason and Human Resources Director) already carry it.

## How this was verified

- **Method:** The headline facts ($15,000 fine, $1,500 × 10 false citations, Rule 375(a)/(b), ARDC referral, ChatGPT provenance) were taken verbatim from the published appellate opinion, 2026 IL App (1st) 251462, and cross-checked against three independent newsrooms (ABA Journal, Human Resources Director, Reason/Volokh).
- **Primary anchor:** the opinion's local PDF SHA-1 (`7599d20bfebd43f1439f3b1d00de49cb0ac16501`, 146,452 bytes) matches the CourtListener published-opinion SHA-1 for cluster 10935788, tying our copy to the court's record.
- **Independent captures:** Reason (web/20260801175602) and Human Resources Director (web/20260730213543) are byte-tied Wayback snapshots; ABA Journal is a flagged live-HTML save (Wayback 403).
- **Date verified:** 2026-08-04; badge set verified 2026-08-27 against the signed opinion (docket 1-25-1462), confirmed not vacated on rehearing or further review. Green rests on the published opinion plus two byte-tied independent captures; it never depends on the sanctioned attorney confirming anything.

## Related case files

- [Whiting v. City of Athens](/stories/whiting-v-city-of-athens-sixth-circuit-fake-citations-15000-punitive-sanction-each-attorney-2026/): the Sixth Circuit case Scott cites as precedent, where the same $15,000 figure was imposed on *each* of two attorneys, not once.
- [In re Martin (N.D. Ill.)](/stories/in-re-martin-nd-ill-bankruptcy-slade-semrad-nield-5500-chatgpt-fabricated-citations-rule-9011-2025/): a same-state Illinois federal sanction, $5,500 under Rule 9011 for ChatGPT-fabricated citations, at a lower rate than the $15,000 this state appellate court set.
- [Torres-Campos v. Munoz](/stories/torres-campos-v-munoz-cal-app-4th-buchanan-5000-ai-fabricated-citations-dog-custody-2026/): a California appellate court's $5,000 sanction for AI-fabricated citations, a lower rate than Illinois deliberately set here.

## Sources

1. Appellate Court of Illinois, First District · *Scott v. Illinois Human Rights Comm'n*, 2026 IL App (1st) 251462 (published opinion, No. 1-25-1462) · 2026-07-28 · https://www.courtlistener.com/opinion/10935788/scott-v-illinois-human-rights-commn/ , **Tier 1** (primary, published appellate opinion; independent-origin, not counted toward corroboration).
2. ABA Journal · "Illinois appeals court imposes higher sanction on attorney to deter 'unacceptable' misuse of AI" · 2026-07-30 · https://www.abajournal.com/news/article/illinois-appeals-court-imposes-higher-sanction-on-attorney-to-deter-unacceptable-misuse-of-ai , **Tier 2** (independent newsroom; archive flagged, Wayback 403, saved as live HTML).
3. Human Resources Director (hcamag) · "Court fines lawyer $15,000 over AI citations in Starbucks bias case" · 2026-07-30 · https://www.hcamag.com/us/specialization/employment-law/court-fines-lawyer-15000-over-ai-citations-in-starbucks-bias-case/584304 , **Tier 2** (independent newsroom; byte-tied Wayback capture).
4. Reason, The Volokh Conspiracy · "'We Do Not Know Why Attorney Cole Feels Compelled to Rush Out Obviously Flawed Filings, but This Must Stop': $15K Sanction" · 2026-07-31 · https://reason.com/volokh/2026/07/31/we-do-not-know-why-attorney-cole-feels-compelled-to-rush-out-obviously-flawed-filings-but-this-must-stop-15k-sanction/ , **Tier 2** (independent legal newsroom; byte-tied Wayback capture).