Obi v. Cook County, Illinois
U.S. District Court, Northern District of Illinois, Eastern Division · N.D. Ill. · Illinois bar guidance
Conduct
A pro se plaintiff's Rule 59(e) motion and replies, which the court found were AI-generated, cited a nonexistent case and quotations absent from real cases and from the court's own order.
Consequence
Here the court struck the motion under Local Rule 7.1 and sanctioned the plaintiff $5,000 under Rule 11, payable within two weeks.
Lesson
Here an earlier filing with 17 fabricated cases, quotes, and statements drew leniency; the repeat drew a $5,000 Rule 11 sanction and loss of page-limit leeway.
Verified September 29, 2026
- Citation
- Obi v. Cook County, Illinois, No. 25 C 3096, Corrected Opinion and Order (N.D. Ill. Apr. 9, 2026) (Kendall, C.J.), ECF No. 97
- Decided
- April 9, 2026
Summary
Ifeoma Delliane Chinedu Obi, representing herself, sued Cook County, a Cook County court, two judges, and several individuals and law firms. The court dismissed her complaint and entered judgment on November 18, 2025. Twelve days later she moved to alter or amend the judgment under Rule 59(e). The motion ran 10.5 single-spaced pages and her two replies 23 and 13 single-spaced pages, without leave and without the table of contents Local Rule 7.1 requires for briefs over 15 pages. Chief Judge Virginia M. Kendall found that "Plaintiff generated each brief using AI" and that the motion was "riddled with AI hallucinations, made up cases, quotes, and statements of law and fact." Examples: a quotation attributed to Marshall v. Marshall, 547 U.S. 293 (2006), that is not in that opinion; "Andrade v. Arby Concessions, 88 F.4th 1014, 1018 (7th Cir. 2023)," which the court said "is not a real case"; language she attributed to page 7 of the court's own dismissal order that is not there; a quotation attributed to Ridder v. City of Springfield that is not in that case; and a false statement about which complaint was operative. The court noted that an earlier filing of hers had contained at least 17 instances of fake cases, quotes, and statements, and that it had then given her "grace."
- AI tool:
- Generative AI, tool not identified (the court states that "Plaintiff generated each brief using AI" and that her motion "is riddled with AI hallucinations")
- Sanction amount:
- $5,000 under Rule 11, payable to the Clerk of the Court within two weeks; Rule 59(e) motion stricken under Local Rule 7.1
What sanction did the court impose?
The court struck the Rule 59(e) motion (and, in the body of the order, the replies) for violating Local Rule 7.1, explaining that it would normally give a pro se litigant leeway on page limits but that her "egregious, repeated, and ongoing Rule 11 violations" foreclosed that. It held that "[t]he severity of Plaintiff's Rule 11 ongoing and repeated violations warrants sanctions," relying on authority that pro se status does not shield a litigant from Rule 11 and that filing nonexistent cases, invented quotations, or arguments unsupported by the record violates the rule. It found that her motion was "so replete with fabricated law, quotes, and statements that there is virtually no cogent argument actually supported by real law." The court sanctioned her $5,000 "for filing false cases, quotes, and statements of law and fact to the Court in violation of Rule 11," payable to the Clerk of the Court within two weeks, citing sanctions of $1,500 to $10,000 imposed or recommended in other hallucinated-citation cases. This is the corrected version of the order; the court's later June 10, 2026 order in the same case has its own entry.
Why does Obi v. Cook County, Illinois matter for law firms using AI?
The April 9 order is the sanctions ruling in Obi’s case, and in it the court tied a page-limit ruling to its Rule 11 findings. Local Rule 7.1 caps briefs at 15 pages without leave and requires a table of contents above that length; the court said it would ordinarily excuse a pro se litigant’s noncompliance. It declined to do so here because the oversized filings were also the vehicle for repeated fabrications; the court added that the missing table of contents was “also problematic because, as discussed below, many of Plaintiff’s citations are fictious.”
On Rule 11, the court treated the filings as a pattern rather than isolated errors. It catalogued fabrications across the motion and both replies, relied on a chart at Dkt. 92-1 identifying 13 hallucinated cases, quotes, and statements of law, and pointed to an earlier filing with at least 17 such items for which the plaintiff had been given leniency. Applying the principle that pro se status “does not shelter plaintiffs from sanctions pursuant to Rule 11,” the court imposed $5,000.
The case continued after this order. On June 10, 2026 the court granted the plaintiff leave to appeal in forma pauperis but found that her notice of appeal repeated a fabricated citation and warned of further sanctions on top of this $5,000; see Obi v. Cook County, Illinois (June 2026). Firms documenting compliance may wish to consider that, in this case, the court’s earlier leniency became part of the record it relied on in imposing the sanction.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Verify any description of the court's own prior order against that order. Here the motion attributed language to page 7 of the dismissal order that the court said is not there.
- Review filings for page-limit and table-of-contents compliance alongside citation checks. The court tied its refusal to extend leeway on Local Rule 7.1 to the plaintiff's repeated Rule 11 violations.
- Document that prior leniency may not recur. The court said it had given the plaintiff 'grace' after an earlier filing with at least 17 instances of fake cases, quotes, and statements of law and fact and that she had 'exhausted that leniency.'