In re S.M., a Minor
Illinois Appellate Court, Fourth District · Ill. App. Ct. (4th Dist.) · Illinois bar guidance
Verified April 26, 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) did 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. Presiding Justice Harris, joined by Justices Steigmann and DeArmond, 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:
- Unspecified generative AI
- 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. illustrates the compounding risk profile of unverified AI use in court-appointed appellate work: every case citation in the brief was invalid, and the panel referred counsel to disciplinary authorities after finding his post-hoc explanations not credible. For managing partners at small and mid-sized firms whose attorneys handle appointed appeals or other high-volume, low-margin docket work, the case underscores that pre-filing citation verification is a non-delegable supervisory responsibility, regardless of caseload economics.
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.