Seventh Circuit Sanctions Attorney for Filing Brief with AI Hallucinations and more...

Seventh Circuit Sanctions Attorney for Filing Brief with AI Hallucinations

The Seventh Circuit Court of Appeals sanctioned a lawyer for AI-generated hallucinations and other inaccuracies and errors in a brief filed with the Court in an immigration appeal. Perez-Castillo v. Todd Blanche.

An attorney filed an opening appellate brief with the Seventh Circuit on behalf of his client, who was appealing an immigration removal order. The Court denied the appeal on its merits in the opinion, and also addressed certain problems and irregularities the Court discovered in the appellate brief. The Court noted that about half of the cases cited in the court filing either did not exist or were falsely labeled as Seventh Circuit cases. The Court also noted that nearly every quotation in the filing could not be traced to a real case, a known hallmark of AI hallucinations. The Court also discovered false representations of the record in the filing, including statements about testimony and findings of the Immigration Judge. On order of the Court, the attorney responded that generative AI was used for the brief but he attributed that to another attorney (who had not filed an appearance in the case). The attorney admitted that he did not review the brief before filing it with the Court

The Court sanctioned the attorney who signed and filed the brief. The sanction (in the amount of $5,000) was based on a violation of the attorney rules of professional conduct rule 46, which authorizes a court to "suspend, disbar, or discipline a member of our bar ‘for conduct unbecoming a member of the bar.’” While the Court did not sanction the attorney who wrote the brief, it did admonish her that she must be cautious in ensuring any use of generative AI is in compliance with the attorney rules of professional conduct. The Court also referred the matter to the Attorney Registration and Disciplinary Commission (ARDC).

The Court ended its opinion with the following cautionary note to litigants and attorneys:

There is “little doubt that litigants and courts” will develop “sound and workable practices” governing AI usage in due time, but that point has not yet arrived. [citation omitted]. Briefs like those petitioner’s counsel submitted in this case are unacceptable and “result in confusion and time wasted” for this court. [citation omitted]. Members of this court’s bar must be exceedingly careful about outsourcing their work product. At all times, attorneys must follow both the Federal Rules of Appellate Procedure and this court’s Rules of Professional Conduct. If not, sanctions may follow.

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School District Administrator Had Qualified Immunity in First Amendment Challenge

The Seventh Circuit Court of Appeals determined that a school district chief talent officer had qualified immunity in a First Amendment case brought by a school district employee who had been terminated for her social media posts in Hayes v. Board of Education.

A college administrator responsible for staffing student teachers in a school district was terminated by the school district for making disparaging comments on social media about the district. The comments included criticisms of the school district and its CEO, including circulating a petition calling for the district to investigate and report on racial inequities in the district. After her termination, she filed a lawsuit against the district's chief talent officer and against the board of education, claiming she was unlawfully retaliated against in violation of her First Amendment rights. The defendants filed a motion for summary judgment, claiming qualified immunity among other defenses, but the district court denied the motion. The defendants appealed to the Seventh Circuit Court of Appeals.

On appeal, the Seventh Circuit determined that the chief talent officer was entitled to qualified immunity against the First Amendment retaliation claim brought by the former employee. Specifically, the Court held that there was no prior caselaw that would put the chief talent officer on notice that his conduct in this case would violate the former employee's constitutional rights, one of the steps in a qualified immunity analysis. As a result, the former employee could not meet her burden to overcome the chief talent officer's qualified immunity defense.

Although the Seventh Circuit found that the chief talent officer had qualified immunity in the case, it allowed the former employee's First Amendment retaliation claim to proceed against the district.

Illinois General Assembly Spring 2026 End of Session Tracking

As the Illinois General Assembly draws closer to concluding its 2026 spring legislative session, there are a number of outstanding bills likely to be considered that would have a significant impact on local governments throughout Illinois. The General Assembly has been busy so far in the 2026 spring session passing a number of bills that will affect local government operations as well as a bill on regulating electric mobility devices. With three days left until the General Assembly recesses on May 31^st, the Governor’s BUILD Plan legislation, and other bills impacting local governments, may still be considered.

Below is a list of bills we’re tracking with updates on the bill’s status through May 28^th.

Housing Legislation

House Bill 5626: BUILD Plan Housing Omnibus Bill (First Reading; referred to House Rules Committee)

Senate Bill 4060: Middle Housing & Statewide Standards (First Reading; referred to Senate Assignments Committee)

Senate Bill 4061: Single-Stair Reform (First Reading; referred to Senate Assignments Committee)

Senate Bill 4062: Statewide Impact Fee Calculation (First Reading; referred to Senate Assignments Committee)

Senate Bill 4063: Third-Party Plan Review (First Reading; referred to Senate Assignments Committee)

Senate Bill 4064: Parking Reform (First Reading; referred to Senate Assignments Committee)

Senate Bill 4071: Accessory Dwelling Units (ADUs) (First Reading; referred to Senate Assignments Committee)

Senate Bill 0331: Restock the Block Act (Second Reading; Senate Floor Amendment No. 1 introduced on May 21^st and recommended for adoption by the Senate Executive Committee)

Senate Bill 0608: Federally Assisted Tenant Protection Act (Second Reading; Senate Floor Amendment No. 1 recommended for adoption by the Senate Executive Committee)

Senate Bill 635: Faith-Based Housing and Mixed-Use By-Right Act (Second Reading; Senate Floor Amendment No.1 recommended for adoption by the Senate Executive Committee)

House Bill 5765 / Senate Bill 4200: REAL Housing Act (Frist Reading; referred to House Rules Committee and Senate Assignments Committee)

Other Legislation Affecting Local Governments

House Bill 1429: Amendments to IL Homeless Bill of Rights (Second Reading; House Floor Amendment No. 1; House Floor Amendment No. 2 recommended for adoption by House Housing Committee; House Floor Amendment No. 3 recommended for approval by House Housing Committee; Bill and all House floor amendments re-referred to House Rules Committee)

House Bill 5513 / Senate Bill 4016: Power Act (First Reading; Bill re-referred to House Rules Committee and Senate Assignments Committee)

House Bill 5326: Digital Library Protection Act (Passed House; House Floor Amendment No.1 and House Floor Amendment No. 2 adopted; First Reading in Senate; referred to Senate Assignments Committee)

House Bill 4712: Amendments to Tax Increment Allocation Redevelopment Act (First Reading; Bill re-referred to House Rules Committee)

Senate Bill 1796: Body Worn Camera FOIA Requests (Senate Committee Amendment No. 2 adopted; Passed Senate; Second Reading in House)

Senate Bill 2715: OMA and FOIA Amendments: (Passed Senate; Second Reading in House; House Committee Amendment No. 1 adopted by House Executive Committee; House Floor Amendments No. 2, No. 3, No. 4, No. 5, No. 6, No. 7 recommended for adoption by House Executive Committee)

House Bill 5784 / Senate Bill 20: Joint Omnibus CBD and Cannabis Regulatory Reform (First Reading in House and referred to House Rules Committee; First Reading in Senate; Senate Floor Amendment No. 1 referred to Senate Assignments Committee)

Legislation Passed By Both Chambers

Senate Bill 3336: Electric Mobility Devices (Passed both houses as of May 27, 2026; awaiting signature by Governor)

Senate Bill 2836: Government Account Audits (Passed both houses as of May 21, 2026; awaiting signature by Governor)

Senate Bill 2826: IMRF Pension Benefits (Passed both houses as of May 21, 2026; awaiting signature by Governor)

Senate Bill 2769: Transfer of Funds Among Municipal Business District Tax Allocation Funds (Passed both houses as of May 21, 2026; awaiting signature by Governor)

Senate Bill 2102: Taxing District Budget and Appropriations Ordinance Filing (Passed both houses as of May 21, 2026; awaiting signature by Governor)

Senate Bill 638: Municipal Postemployment Benefit Trusts (Passed both houses as of May 21, 2026; awaiting signature by Governor)

Senate Bill 2761: Service Animals and In-Service ADA Trainings (Passed both houses as of May 21, 2026; awaiting signature by Governor)

Senate Bill 2913: Teacher Evaluation Plans (Passed both houses as of May 21, 2026; awaiting signature by Governor)

Senate Bill 2914: Procedure for Removing/Dismissing Teachers (Passed both houses as of May 21, 2026; awaiting signature by Governor)

Senate Bill 3361: Religious Hairstyles in Schools (Passed both houses as of May 21, 2026; awaiting signature by Governor)

House Bill 4375: School District Interfund Transfers (Passed both houses as of May 21, 2026; awaiting signature by Governor)

House Bill 5542: Park District Disconnection Petitions (Passed both houses as of May 21, 2026; awaiting signature by Governor)

House Bill 5166: Dissolution of Special Districts (Passed both houses as of May 21, 2026; awaiting signature by Governor)

House Bill 5167: Township Weed Cutting (Passed both houses as of May 21, 2026; awaiting signature by Governor)

House Bill 4788: Cardiopulmonary Resuscitation Training Curriculum (Passed both houses as of May 20, 2026; awaiting signature from Governor)

House Bill 4862: School Staff Mental Health Policies (Passed both houses as of May 20, 2026; awaiting signature from Governor)

House Bill 4491: Amendment to Public Employee Disability Act (Passed both houses as of May 20, 2026; awaiting signature by Governor)

House Bill 2137: Amendment to Governmental Account Audit Act (Passed both houses as of May 20, 2026; awaiting signature by Governor)

House Bill 4397: School Psychologist Qualifications (Passed both houses as of May 19, 2026; awaiting signature by Governor)

House Bill 3743: School District Handbook Railroad Safety Messaging (Passed both houses as of May 19, 2026; awaiting signature by Governor)

House Bill 4137: Amendment to Education for Homeless Children Act (Passed both houses as of May 19, 2026; awaiting signature by Governor)

House Bill 4361: Building Inspector Certifications (Passed both houses as of May 19, 2026; awaiting signature by Governor)

House Bill 1353: Amendment to Volunteer Emergency Worker Job Protection Act (Passed both houses as of May 19, 2026; awaiting signature by Governor)

House Bill 4541: Revised Uniform Unclaimed Property Act (Passed both houses as of May 14, 2026; awaiting signature by Governor)

Post Authored by Tyler Smith, Ancel Glink

Police Search of Backpack During Arrest Was Lawful

Federal appeals court rules against arrestee in challenge to police officer's seizure of backpack during arrest in U.S. v. Fillyaw.

Local police officers executed a search warrant and arrested an individual in connection with an arson investigation. During the arrest (which took place in an apartment parking lot), police seized the arrestee's backpack and searched the contents, finding a loaded handgun and drugs. The arrestee filed a motion to suppress the evidence found in the backpack, arguing that the search violated his Fourth Amendment rights. The district court and Seventh Circuit Court of Appeals ruled in favor of the police, holding that police have the right to take custody of an arrestee's property and take inventory of that property when the arrest takes place in a public place.

Seventh Circuit Rejects Discrimination Claim by Candidate for Deputy Sheriff Position

The Seventh Circuit Court of Appeals upheld a county sheriff office's decision not to hire a candidate for a deputy sheriff position, rejecting the candidate's racial discrimination claim in Burton v. Will County Sheriff's Merit Commission.

A candidate applied for a deputy sheriff position with a county sheriff's department. As part of the background check process, the county contacted the candidate's current employer, who stated that he was not a dependable employee, did not work well with others, and that the employer would not rehire him. Based on that information, the county sheriff's commission removed the candidate from the hiring certification process. He sued, claiming that the county discriminated against him because of his race.

The district court ruled in favor of the county, finding no evidence that the decision to remove the candidate from the hiring certification process was related to his race. On appeal, the Seventh Circuit Court of Appeals agreed with the district court, finding no evidence that race played a role in the sheriff's merit commission's decision, rejecting the candidate's argument that the negative background check was a pretext to remove him from consideration. Instead, the Court found that the county had a legitimate, nondiscriminatory reason to remove him - the negative employment reference from his current employer.

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