In re Baby Boy and A.H., Minors
Appellate Court of Illinois, Fourth District · Ill. App. Ct. (4th Dist.) · Illinois bar guidance
Verified May 5, 2026
- Citation
- In re Baby Boy and A.H., 2025 IL App (4th) 241427, Nos. 4-24-1427, 4-24-1430 cons. (Ill. App. Ct. 4th Dist. July 21, 2025)
- Decided
- July 21, 2025
Summary
Court-appointed appellate counsel William T. Panichi cited eight nonexistent cases across the opening and reply briefs in a parental-rights termination appeal, including a fabricated quotation attributed to a nonexistent Second District decision. Justice Lisa Holder White Zenoff, writing for a unanimous panel with Justices Lannerd and Knecht, found that Panichi used AI to draft the briefs without verifying any citations and then misrepresented to the court that several fictitious cases were "properly cited." The panel held Panichi willfully violated Illinois Supreme Court Rule 375 and Rules of Professional Conduct 1.1, 3.1, 3.3, and 8.4(c).
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $7,925.62
What sanction did the court impose?
Panichi ordered to disgorge the $6,925.62 in court-appointed fees he received from the Sangamon County treasurer, pay an additional $1,000 fine to the clerk of the Fourth District Appellate Court, and the clerk was ordered to forward the opinion to the Illinois Attorney Registration and Disciplinary Commission. Request to file an amended brief was denied; the underlying termination of parental rights was affirmed.
Why does In re Baby Boy and A.H., Minors matter for law firms using AI?
This is the first published Illinois Appellate Court opinion sanctioning an attorney for filing AI-generated fictitious case citations, and the court framed it as a deterrent for the Illinois bar. The case is notable for state bar compliance reasons: the panel grounded its analysis in the Illinois Supreme Court’s January 2025 AI Policy and Rule of Professional Conduct 1.1’s competence duty, then forwarded the matter to the ARDC. Firms supervising appointed or appellate work in Illinois should treat this as the controlling Illinois precedent on AI-citation discipline.
Sources
Primary 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.