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

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. 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. 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.

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. An independent trade newsroom reported the same concession: “The lawyer conceded he used ‘a premier corporate subscription of ChatGPT’ to draft filings” source. 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.

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. 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. 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; Human Resources Director wrote it “ordered him to pay $15,000 - $1,500 for each of 10 false citations” source; and Reason’s Volokh Conspiracy noted “The court sanctioned Cole $15,000” source. 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, a referral Human Resources Director also reported source.

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: 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.): 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: 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).