In re A.S., I.P., J.P., and S.S. (Julian S., Respondent-Appellant)
Appellate Court of Illinois, Fourth District · Ill. App. Ct. · Illinois bar guidance
Verified April 26, 2026
- Citation
- In re A.S., 2025 IL App (4th) 250300-U, 2025 Ill. App. Unpub. LEXIS 1371 (Ill. App. Ct. Aug. 4, 2025) (Nos. 4-25-0300, 4-25-0301, 4-25-0302, 4-24-0298, cons.)
- Decided
- August 4, 2025
Summary
Appellate counsel William T. Panichi filed briefs containing one citation to a case that did not exist ("In re C.M., 2015 IL App (3d) 140876") and seven existing cases, including one nonprecedential order entered pursuant to Illinois Supreme Court Rule 23(b), that did not stand for the propositions of law for which they were cited. Justice Knecht, writing for a panel that included Justices Doherty and DeArmond, found Panichi violated Illinois Supreme Court Rule 375 and inferred AI use based on the briefing, Panichi's response to the rule to show cause, and his prior June 2025 sanction in In re Baby Boy for similar conduct in which he admitted using AI without thorough review.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,000
What sanction did the court impose?
Appeals dismissed for lack of jurisdiction. The court ordered Panichi to pay $1,000 in monetary sanctions to the clerk of the Fourth District Appellate Court and ordered the clerk to send a copy of the decision to the Illinois Attorney Registration and Disciplinary Commission (ARDC).
Why does In re A.S., I.P., J.P., and S.S. (Julian S., Respondent-Appellant) matter for law firms using AI?
This is the second Rule 375 sanction the Fourth District imposed on Attorney Panichi within roughly six weeks, following In re Baby Boy, 2025 IL App (4th) 241427, where he admitted using AI and committed not to continue doing so. For managing partners, the case illustrates that Illinois appellate courts now treat repeat unverified-citation conduct as grounds for both monetary sanctions and ARDC referral, and will infer AI use from the pattern of citations even when counsel does not admit it. The court was explicit that AI use itself is not the violation; the failure to verify work product before filing is.
Sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.