In re S.M., a Minor
Illinois Appellate Court, Fourth District · Ill. App. Ct. (4th Dist.) · Illinois bar guidance
Verified September 29, 2026
- Citation
- In re S.M., 2025 IL App (4th) 250277-U, No. 4-25-0277 (Ill. App. Ct. 4th Dist. Aug. 7, 2025)
- Decided
- August 7, 2025
Summary
Attorney William T. Panichi, court-appointed appellate counsel for the respondent mother in a parental rights termination appeal, filed an appellant's brief containing only four case citations, all of them invalid. Two cases (In re M.M., 2015 IL App (4th) 150203, and In re A.P., 2017 IL App (4th) 170070) "based on research performed, do not exist"; two real cases (In re C.N., 196 Ill. 2d 181 (2001), and In re D.D., 196 Ill. 2d 405 (2001)) were cited for propositions they did not support. The court (Harris, P.J., with Steigmann and DeArmond, JJ., concurring in the judgment) found Panichi's responses to the rule to show cause "disingenuous and misleading" and concluded he had willfully violated Illinois Supreme Court Rule 375.
- AI tool:
- Not mentioned in the order
- Sanction amount:
- $1,000
What sanction did the court impose?
$1,000 monetary sanction payable to the clerk of the Fourth District Appellate Court, with the clerk directed to send a copy of the decision to the Illinois Attorney Registration and Disciplinary Commission (ARDC).
Why does In re S.M., a Minor matter for law firms using AI?
In re S.M. rests a willfulness finding on two things: the four case citations in the brief “were the only case citations” counsel included, and “all four are invalid,” and counsel’s explanations in response to the rule to show cause were “both disingenuous and misleading.” The court imposed a $1,000 sanction under Rule 375, following its decision in In re Baby Boy, and directed the clerk to send the decision to the ARDC. The order does not say how the citations were produced. For firms whose attorneys take appointed appeals, the order shows that an explanation the court finds not credible can weigh as heavily as the citations themselves.
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.