June 1, 2026 (in 3 days): New York: 22 NYCRR Part 161 takes effect, system-wide AI policy for all UCS courts →

D'Angelo v. Vaught

Illinois Appellate Court · Ill. App. · Illinois bar guidance

Court sanction

Verified April 26, 2026

Citation
D'Angelo v. Vaught (Ill. App. Apr. 2, 2025)
Decided
April 2, 2025

Summary

Per the Charlotin AI Hallucination Cases Database lead, an Illinois Appellate Court order dated April 2, 2025 sanctioned counsel for filing a brief that cited fabricated authorities generated by Archie, the AI assistant built into Smokeball's legal practice management platform. The court imposed a $2,000 monetary sanction. Substantive details (sanctioned attorney's name, panel judges, exact docket, fabrication count, underlying cause of action) could not be verified from primary sources during this pass: the Charlotin-hosted PDF copy of the order is an image-only scan that is not text-extractable, and no CourtListener docket, Illinois courts.gov opinion page, Justia mirror, or Volokh/Reason write-up surfacing this caption was located.

AI tool:
Archie (Smokeball)
Sanction amount:
$2,000
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

What sanction did the court impose?

$2,000 monetary sanction (per Charlotin database). Other consequences (CLE, ARDC referral, disgorgement) not confirmed.

Why does D'Angelo v. Vaught matter for law firms using AI?

D’Angelo is a notable data point because the AI tool implicated is not a general-purpose chatbot but Archie, a legal-vertical assistant marketed by practice-management vendor Smokeball directly to small and mid-sized US firms. For a managing partner, that distinguishes this case from the Mata v. Avianca lineage: a “lawyer-built” AI sold into the firm’s existing tech stack still produced fabricated authorities that reached a court filing. The verification rule does not bend for vendor branding. Pending location of the underlying order text, this entry is a placeholder; the Charlotin-hosted PDF is image-only and the full opinion has not yet been mirrored by CourtListener, Justia, or the Illinois courts site as of the verification date.

Related on this site

Topic guides

  • Billing for AI Work: ABA Model Rule 1.5 and the state opinions on billing for AI-assisted legal work. Hourly billing, flat-fee adjustments, expense pass-through,…
  • Supervised AI Use: ABA Model Rule 5.1, Rule 5.3, and the state opinions that translate them into firm-side duties to supervise AI tools and the people using th…

Court orders

Sanctions cases

From the blog

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.

Unverified claims:
  • Sanctioned attorney's name not extracted (Charlotin PDF is an image-only scan; no OCR text available).
  • Specific Illinois Appellate District (First, Second, Third, Fourth, or Fifth) not confirmed.
  • Exact docket number and Bluebook neutral citation (e.g., 2025 IL App (Xd) XXXXXX) not located.
  • Panel judges not identified.
  • Number and identity of fabricated citations not confirmed.
  • Whether the order included additional non-monetary sanctions (ARDC referral, CLE, disgorgement) not confirmed.
  • Underlying subject matter of the appeal not confirmed.
  • Confirmation that Smokeball's Archie tool was the named AI source in the order itself (versus inferred from lead) not obtained.