In re R.L.
Appellate Court of Illinois, Fourth District · Ill. App. 4th Dist. · Illinois bar guidance
Verified May 14, 2026
- Citation
- In re R.L., 2025 IL App (4th) 241211-U (Ill. App. 4th Dist. Aug. 20, 2025) (No. 4-24-1211)
- Decided
- August 20, 2025
Summary
Appellate counsel William T. Panichi filed a brief that included a fabricated citation to "In re C.P., 2018 IL App (4th) 180378," a case that does not exist (the actual In re C.P. from the Fourth District in 2018 is 2018 IL App (4th) 180310). The Fourth District identified the defective citation and addressed Rule 375 in light of Panichi's prior conduct in In re Baby Boy and the In re A.S. and In re S.M. appeals, where the same attorney had already been sanctioned and referred to the ARDC for AI-related fabrications.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No additional monetary sanctions were imposed in this appeal because Panichi had already been sanctioned in In re Baby Boy, 2025 IL App (4th) 241427, and in parallel matters including In re A.S., 2025 IL App (4th) 250298-U, and In re S.M., 2025 IL App (4th) 250277-U, with the prior orders forwarded to the Illinois Attorney Registration and Disciplinary Commission.
Why does In re R.L. matter for law firms using AI?
In re R.L. is the third Fourth District opinion in roughly two months documenting AI-fabricated citations by the same appellate attorney, following In re Baby Boy and the consolidated In re A.S. appeals. For managing partners, the case shows that Illinois appellate panels will decline to stack additional monetary sanctions when prior orders in parallel matters have already been entered and referred to the ARDC, but will continue to publish the misconduct on the public record. The pattern, not any single fee award, is what now drives discipline exposure for repeat offenders.
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.