In re R.L.

How did the court address the AI-related conduct?

The court affirmed and imposed no sanction in this appeal. It explained (¶ 118): "although Panichi has cited nonexistent cases and cases that do not stand for the propositions of law asserted, because Panichi has already been referred to the ARDC and is surrendering his license, we have elected to not pursue sanctions in the present case, which would require further rule to show cause proceedings and cause further delay."

Why does In re R.L. matter for law firms using AI?

In re R.L. follows three Fourth District decisions from the preceding month (In re Baby Boy, In re A.S. and In re S.M.) that sanctioned the same appellate attorney for nonexistent or unsupported citations. Here the court identified a nonexistent case but “elected to not pursue sanctions” because counsel had already been referred to the ARDC and was surrendering his license, and because a further rule to show cause proceeding would have further delayed a termination-of-parental-rights decision. The court also noted that addressing counsel’s conduct across these appeals “caused further delay in the issuance of our decision.” For firms, the order shows that the costs of unverified citations can fall on the client and the case timeline even when no sanction is entered.