Pletcher v. Village of Libertyville Police Pension Board
Appellate Court of Illinois, Second District · Ill. App. 2d Dist. · Illinois bar guidance
Conduct
Appellant pro se filed brief almost wholly AI-generated containing five fictitious Illinois case citations.
Consequence
Brief stricken; appeal dismissed under Illinois Supreme Court Rule 375(a).
Lesson
Ill. App. 2d Dist. will dismiss the entire appeal, not just strike the offending citations, when the brief is substantively AI-generated.
Verified May 7, 2026
- Citation
- Pletcher v. Village of Libertyville Police Pension Bd., 2025 IL App (2d) 240416-U (Nov. 24, 2025)
- Decided
- November 24, 2025
Summary
Bryan Pletcher, a former Village of Libertyville police officer appealing a pension board denial of non-duty disability benefits, filed an appellate brief that the Second District found "almost wholly created with the aid of artificial intelligence." Justice Hutchinson, writing for a panel that included Justices Birkett and Mullen, identified five fictitious case citations: Pravdic v. Board of Trustees of the University of Illinois, 2013 IL App (1st) 220689; Hoffman v. Retirement Board of Fireman's Annuity, 2020 IL App (1st) 190182; Schoenbeck v. Board of Trustees of the Police Pension Fund of the Village of Oak Lawn, 2021 IL App (1st) 200557; Pedrick v. Village of Downers Grove, 115 Ill. App. 3d 315 (1983); and Krahel v. Oakbrook Terrace Firefighters' Pension Board, 2021 IL App (2d) 200165. The appellant appeared at oral argument on November 6, 2025 and accepted responsibility for the AI-generated citations.
- AI tool:
- Unspecified generative AI (admitted by appellant at oral argument)
What sanction did the court impose?
Defendant pension board's motion for sanctions under Illinois Supreme Court Rule 375(a) granted. Appellant's brief stricken; appeal dismissed.
Why does Pletcher v. Village of Libertyville Police Pension Board matter for law firms using AI?
Justice Hutchinson struck the brief and dismissed the appeal outright. She did not order the brief re-filed or merely strike the offending citations. Five fictitious Illinois case citations had been identified, and Pletcher accepted responsibility at oral argument on November 6, 2025. Rule 375(a) supplied the sanctions authority.
This is the Second District’s first publicly available Rule 375(a) dismissal premised on AI-generated content. It issued as an unpublished Rule 23 order (citation suffix “-U”) with the limited precedential weight that designation carries. Rule 375(a) dismissals at the appellate level for AI content are themselves novel; more common are citation-verification orders or Rule 341 brief-format rulings. Here the panel treated AI generation itself as the sanctionable conduct, not just the resulting fictitious citations. That tracks the Illinois Supreme Court’s January 2025 AI policy, which places verification duty on the filer regardless of tool.
Illinois firms handling pension or municipal-employee appeals before the Second District face a new risk. An AI-generated brief by an unrepresented appellant can produce outright dismissal with prejudice for the adverse party. Defendant pension boards now have a Rule 375(a) theory ready on the first AI-citation flag. Second District practice shows the panel will grant the sanction at dismissal level, not at brief-strike level.
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.
- When briefing pension board appeals in the Second District, expect heightened scrutiny of every cited case; an AI-generated brief is now a Rule 375(a) trigger for outright dismissal.
- Document the firm's process for verifying every Illinois Supreme Court Rule 23 unpublished order cited in an appellate brief; fictitious 'IL App' cites resolve to nothing on Westlaw or the Illinois Courts opinion search.
- For pro se appellants, the Pletcher result is a useful citation when seeking dispositive relief against a brief that opposing counsel suspects is AI-generated: the Second District will dismiss the appeal rather than allow a re-filed brief.