In re A.S.
Appellate Court of Illinois, Fourth District · Ill. App. (4th) · Illinois bar guidance
Conduct
Court-appointed appellate counsel filed juvenile-protection briefing with 1 nonexistent case and 7 misrepresented holdings.
Consequence
$1,000 monetary penalty payable to court clerk; ARDC referral; no fee disgorgement (unlike Panichi's parallel In re Baby Boy sanction).
Lesson
Ill. App. 4th Dist.: appointed-counsel AI hallucinations escalate; prior admission in a parallel case suffices to infer AI use.
Verified May 8, 2026
- Citation
- In re A.S., 2025 IL App (4th) 250298-U (Aug. 4, 2025) (Knecht, J.)
- Decided
- August 4, 2025
Summary
In a consolidated juvenile-protection appeal (In re A.S., I.P., J.P., S.S., docketed as 4-25-0298, 4-25-0300, 4-25-0301, 4-25-0302), the Appellate Court of Illinois, Fourth District, found that court-appointed appellate counsel William T. Panichi had filed briefing containing one entirely nonexistent case (In re C.M., 2015 IL App (3d) 140876) and seven real cases cited for propositions they did not support. Panichi had been the same attorney sanctioned weeks earlier in In re Baby Boy, 2025 IL App (4th) 241427, where he admitted using generative AI to draft his briefing. In A.S. Panichi did not admit AI use, but the panel inferred AI use from the briefing pattern and Panichi's prior admission in the parallel matter.
- AI tool:
- Generative AI inferred (Justice Knecht: 'a reasonable conclusion based upon our review of the briefing'; counsel did not admit AI use in this case but had admitted to it weeks earlier in In re Baby Boy)
What sanction did the court impose?
Justice Knecht (joined by Justices Doherty and DeArmond, concurring) imposed a $1,000 monetary penalty payable to the Fourth District Appellate Court clerk and referred Panichi to the Illinois Attorney Registration and Disciplinary Commission. The sanction did not include fee disgorgement (distinct from In re Baby Boy, which required Panichi to disgorge $6,925.62 in fees). The court's rationale emphasized that the AI-citation problem in juvenile cases is amplified by the time-sensitive procedural posture and the appointed-counsel context: the children's interests cannot bear the cost of fabricated citations that delay resolution.
Why does In re A.S. matter for law firms using AI?
In re A.S. is the Fourth District’s second AI-citation sanction against attorney William T. Panichi in a five-week window, following In re Baby Boy, 2025 IL App (4th) 241427. In Baby Boy, Panichi admitted to using generative AI to draft his appellate briefing and was ordered to disgorge $6,925.62 in court-appointed appellate fees. In A.S. (consolidating four juvenile-protection appeals on behalf of respondent-father Julian S.), Panichi did not admit AI use, but the Knecht panel inferred AI use from the briefing pattern (one entirely nonexistent citation plus seven misrepresented holdings) and from Panichi’s prior admission in the parallel case. The panel applied a $1,000 monetary penalty payable to the court clerk plus an ARDC referral. The remedy structure is distinct from Baby Boy: no fee disgorgement, in part because the Knecht panel treated the underlying conduct as a pattern rather than a single failure.
For Illinois Appellate practitioners representing institutional clients, the doctrinal point is that the Fourth District will treat a prior AI-use admission in a parallel case as factual support for inferring AI use in a later case from the same counsel, even without a fresh admission. The juvenile-protection posture also elevates the panel’s concern: the court emphasized that fabricated citations in time-sensitive juvenile matters impose costs on the children’s interests, not just the litigation parties. The opinion is a useful authority for any sanctions briefing that asks an Illinois Appellate panel to draw on counsel’s broader AI-citation track record when calibrating remedies. The Knecht quote that “it is not the use of AI itself that is concerning; rather, it is the apparent failure to thoroughly review the work-product therefrom before submitting it to court” is the cleanest articulation of the Fourth District’s posture on AI use generally.
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.
- In re A.S. is the second Panichi sanction in five weeks; the Fourth District panel treated the prior In re Baby Boy admission as factual support for the AI-use inference here, even without a fresh admission. Firms practicing in Illinois Appellate should expect appellate panels to draw on a counsel's track record across cases when calibrating AI-citation findings.
- Juvenile-protection cases are time-sensitive procedurally; the panel's reasoning emphasizes that fabricated citations in this posture impose costs on children's interests rather than just the opposing party. Cite In re A.S. for the proposition that AI-citation harms scale with the procedural urgency of the matter, not just the substantive merits at issue.
- The penalty regime here is monetary ($1,000 to court clerk) plus ARDC referral, distinct from the fee-disgorgement remedy in In re Baby Boy. Firms tracking Illinois Appellate sanctions should note this graduated remedy structure: disgorgement is reserved for cases where appointed-counsel fees would otherwise compensate hallucinated work-product.