Feldman v. District 6 Board of Education
U.S. District Court, Central District of Illinois · C.D. Ill. · Illinois bar guidance
Conduct
Plaintiffs' response to a motion to dismiss cited nonexistent cases and attributed unsupported propositions to real cases.
Consequence
No sanction; the court warned that future false citations will result in a show cause hearing and consideration of sanctions.
Lesson
Here the court flagged the citations in a footnote to its merits ruling and reserved sanctions for any repetition.
Verified May 9, 2026
- Citation
- Feldman v. District 6 Board of Education, 2026 U.S. Dist. LEXIS 69063 (C.D. Ill. Mar. 31, 2026) (Lawless, J.)
- Decided
- March 31, 2026
Summary
In a student disability and harassment case, plaintiffs' response to defendants' motion to dismiss cited nonexistent cases and attributed unsupported propositions to real ones. In a footnote, Judge Colleen R. Lawless wrote that "[t]hroughout their response Plaintiffs cite nonexistent cases or contend that cases, although real, stand for wholly unsupported or undiscussed legal conclusions." The court's examples: "Doe v. Madison Metro. Sch. Dist., 43 F.4th 963, 969 (7th Cir. 2022)," cited for the proposition that sexual harassment need not involve animus based on gender stereotypes, "does not appear to exist, along with many others"; and plaintiffs quoted Rost v. Steamboat Springs RE-2 Sch. Dist., 511 F.3d 1114 (10th Cir. 2008), but "[a]lthough the case exists, the quote does not, and the proposition the case is cited for was not a point of discussion."
- AI tool:
- Not mentioned in the order
What did the court warn about?
No sanction imposed. The court granted the motion to dismiss in part and denied it in part, gave plaintiffs 21 days to file an amended complaint, and warned 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."
Why does Feldman v. District 6 Board of Education matter for law firms using AI?
Feldman v. District 6 Board of Education shows a court addressing nonexistent and misrepresented citations in a footnote to its merits ruling and reserving sanctions for any repetition. Judge Lawless identified two problems: a cited case that “does not appear to exist, along with many others,” and a quotation attributed to a real case where “the quote does not” exist and “the proposition the case is cited for was not a point of discussion.” The order does not mention AI.
The consequence is a warning in the order’s conclusion: any future false citations “will result in a show cause hearing and consideration of sanctions.” No fee, strike or disclosure requirement was imposed on the filing at issue. Firms documenting their citation-review practices may wish to note that the court treated misattributed quotations and unsupported propositions the same way as nonexistent cases.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- The court raised the citation problems in a footnote to its ruling on the motion to dismiss, without a separate sanctions proceeding, so problems can surface in any merits order.
- The warning covers both fabrication and misrepresentation: nonexistent cases, cases cited for propositions they do not discuss, and other false representations.
Sources
Primary sources
- AI attribution: the order does not mention artificial intelligence or say how the citations were produced. The entry is included because third-party AI hallucination trackers list it.