Feldman v. District 6 Board of Education
U.S. District Court, Central District of Illinois · C.D. Ill. · Illinois bar guidance
Verified April 26, 2026
- Citation
- Feldman v. District 6 Board of Education, No. 3:25-cv-03002-CRL-DJQ (C.D. Ill. Mar. 31, 2026)
- Decided
- March 31, 2026
Summary
Plaintiffs' counsel submitted a response to a motion to dismiss that cited nonexistent cases and misrepresented real ones. In a footnote, Judge Colleen R. Lawless flagged a citation to "Doe v. Madison Metro. Sch. Dist., 43 F.4th 963 (7th Cir. 2022)" as a case that "does not appear to exist, along with many others." Plaintiffs also cited Rost v. Steamboat Springs RE-2 Sch. Dist., 511 F.3d 1114 (10th Cir. 2008), for an ostensible quote that sexual harassment includes "conduct of a sexual nature": the court found the case exists but "the quote does not, and the proposition the case is cited for was not a point of discussion."
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction was imposed. The court ruled on the motion to dismiss on the merits and warned plaintiffs that "any future citation to nonexistent cases, cases for legal propositions not discussed or supported, or other false representations to the Court will result in a show cause hearing and consideration of sanctions." Plaintiffs were given 21 days to file an amended complaint.
Why does Feldman v. District 6 Board of Education matter for law firms using AI?
Feldman illustrates the increasingly common pattern of judges flagging fabricated and misrepresented citations in a routine footnote rather than separate sanctions order, paired with an explicit show-cause warning for any repeat conduct. For managing partners, the case is a reminder that even when no fees are awarded, a published opinion identifying counsel’s filing as containing nonexistent cases is itself a discoverable, reputationally durable record.
Sources
Further reading
- CourtListener docket search (aggregator)
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
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.