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 notice of appeal attributed a made-up quotation and a nonexistent Seventh Circuit case to the district court's own dismissal order.
Consequence
Here the court granted in forma pauperis status on appeal but warned of 'even more serious sanctions' on top of an earlier $5,000 Rule 11 sanction.
Lesson
In this case the court tested the notice of appeal against its own prior order and found the claimed acknowledgment, quote, and case all made up.
Verified September 29, 2026
- Citation
- Obi v. Cook County, No. 25 C 3096, Opinion and Order (N.D. Ill. June 10, 2026) (Kendall, C.J.), ECF No. 108
- Decided
- June 10, 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 without prejudice in November 2025. When she moved to alter or amend the judgment, the court, in an April 9, 2026 order, struck the motion for violating Local Rule 7.1 and sanctioned her $5,000 under Rule 11, ruling that "[t]he severity of Plaintiff's Rule 11 ongoing and repeated violations warrants sanctions." She appealed and sought leave to proceed on appeal in forma pauperis. Reviewing her 15-page single-spaced notice of appeal, Chief Judge Virginia M. Kendall found that Obi "continues to submit AI hallucinated arguments and cases." The notice asserted that the court had "acknowledged on page 7" of its dismissal order that a federal court may hear a claim that a state judgment is void, citing "Andrade v. Arby Concessions, 88 F.4th 1014 (7th Cir. 2023)." The court found that "[t]he entirety of that assertion [...] is made up" (the quote, the case, and the claimed acknowledgment), and called Obi "a repeat offender on this front" who "has continually filed briefs generated by AI that are riddled with fabricated cases and arguments."
- AI tool:
- Generative AI, tool not identified (the court states that the plaintiff 'continues to submit AI hallucinated arguments and cases' and has 'continually filed briefs generated by AI')
What did the court warn about?
The court granted Obi leave to proceed on appeal in forma pauperis. Although it found several of her positions frivolous and said it was "concerning that Obi continues to improperly rely on AI, submit fabricated law and facts, and ignore basic Court rules," it could not conclude that the appeal as a whole was brought in bad faith, and it found five of her six stated issues not frivolous. In a footnote addressed to Obi directly, the court warned that she remains bound by Rule 11 on appeal and that if she continues "to submit false cases, statements, or quotes (whether generated by AI or not), you may be subject to even more serious sanctions on top of the $5,000 you are currently ordered to pay." Another footnote notes she is under order to pay the $5,000 sanction by September 28, 2026. This order imposes no new sanction.
Why does Obi v. Cook County, Illinois matter for law firms using AI?
The June 10 order is a routine ruling on in forma pauperis status on appeal, but it records a sustained pattern. The court had already sanctioned Obi $5,000 under Rule 11 in April 2026 after striking her motion to alter or amend the judgment. Her notice of appeal then repeated the problem: it asserted that the district court had itself acknowledged a legal proposition on page 7 of its dismissal order, and it supplied a Seventh Circuit citation for it. Chief Judge Kendall compared the claim with her own order and found that the quote, the case, and the acknowledgment were all made up.
The court nonetheless granted leave to appeal without prepaying fees. Applying the rule that good faith is judged on the appeal as a whole, it found that at least some of Obi’s six issues were not frivolous, so the privilege had to be allowed even though other positions were frivolous and her reliance on AI was, in the court’s words, “concerning.”
The warning in the footnote is addressed to Obi by name and makes clear the court’s view that the source of false citations does not matter: false cases, statements, or quotes, “whether generated by AI or not,” may lead to more serious sanctions on top of the existing $5,000.
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 every description of a court's own prior ruling against that ruling. Here the claimed 'acknowledgement' on page 7 of the dismissal order did not exist.
- Consider that an earlier monetary sanction does not end the court's scrutiny. The court reminded the plaintiff that Rule 11 applies on appeal and that further false citations could bring additional sanctions.
- Document compliance with page-limit and spacing rules alongside citation checks; the court listed disregard of those rules with the fabricated authority.
Sources
Primary sources
- The April 2026 Rule 11 sanctions order (docketed as ECF No. 96 on April 7, 2026 and a corrected version, ECF No. 97, on April 9, 2026) is not in the RECAP archive and was not read. Its $5,000 amount, the striking of the Rule 59(e) motion, and the quoted ruling are taken from this June 10 order's description of it and from the CourtListener docket text.
- The specific fabricated authorities that led to the April sanction are not identified in this order.