Cole v. Hobby Town Unlimited, Inc.

What sanction did the court impose?

Judge Sara Darrow held that Reyes's "citation to non-existent cases and misrepresentation of others is not objectively reasonable, and thus merits sanctions" under Rule 11. She ordered him to pay a $1,000 fine to the Clerk of Court within sixty days, to send a copy of the order to the Illinois Attorney Registration and Disciplinary Commission, and to file a status report on his compliance within sixty days. The court said the sanction was warranted not because the four citation errors were particularly egregious but because of the context: it was "utterly unconvinced" by his apology and corrective measures given the Pittman history, calling this "at least the third case in which he has filed briefings with AI hallucinations," found that prior conduct and deterrence supported a monetary sanction, and treated the fact that the citations advanced the client's arguments as cancelling out the mitigating weight of the small number of errors. It described his earlier sanctions as "relatively lenient," listing a stricken filing in Pittman and a March 19, 2026 Pittman order that required him to report to the ARDC and pay fees and costs and dismissed that case with prejudice. It noted that he offered his cooperation with "an ongoing ARDC investigation" as a corrective measure. No fees were awarded because none were timely requested.

Why does Cole v. Hobby Town Unlimited, Inc. matter for law firms using AI?

Cole turns on what the lawyer had already been told, not on the severity of the errors. Judge Darrow said so directly: significant and monetary sanctions were appropriate “not because the citation errors themselves were particularly egregious” (there were four, supporting generally accepted propositions) “but because of the context in which Reyes engaged in this conduct.” That context came largely from Reyes’s own response, which invoked his conduct in Pittman v. Hazel & Olive as a reason for leniency. The court noted in a footnote that by relying on Pittman he “put it directly at issue.”

The court read the Pittman record against him. In January 2026 a Northern District of Illinois judge struck his brief for hallucinated cases, and on January 20 he told that court, as quoted in the order, that “[g]oing forward, no citation or quotation will be included in any filing unless it has been independently verified against the underlying opinion in Westlaw or Lexis prior to submission.” “Just seven days later, on January 27, 2026,” he filed the motion here, which the court describes as nearly identical to the Hippe motion “down to the hallucinations.” The court concluded that Reyes “either disingenuously represented to the Pittman court that he had implemented corrective measures […] or those measures were implemented in an entirely ineffective manner,” and that his response to the show-cause order was, “at first review, quite compelling” but that his “contrition unravels, however, upon closer examination.”

The court described the $1,000 sanction as modest relative to other recent sanctions, and it noted in closing that “the only consequence Reyes had suffered by the time he filed the motion for default judgment in this case was a stricken motion.” Firms documenting compliance may wish to consider that, in this case, the court weighed a remediation promise made to a different court as part of the record, so the credibility of a firm’s corrective measures can carry from one matter to the next.