Sharky's Sports Bar v. Village of Mt. Morris, Illinois
U.S. District Court, Northern District of Illinois, Western Division · N.D. Ill. · Illinois bar guidance
Verified April 26, 2026
- Citation
- Sharky's Sports Bar v. Village of Mt. Morris, No. 3:24-cv-50457 (N.D. Ill. Dec. 10, 2025)
- Decided
- December 10, 2025
Summary
In a memorandum opinion denying defendants Heather and Brock Swanlund's motion for judgment on the pleadings, Judge Iain D. Johnston included a section titled "A Brief Word on Generative AI" flagging erroneous citations in the Swanlunds' earlier motion to dismiss (Dkt. 176). The order found that Rowe v. State of Lombard exists but its reporter volume and first page were misrepresented, and that O'Sullivan v. City of Chicago cases exist but their reporter volume, first page, date, and court were all misrepresented, with none of the real O'Sullivan cases supporting the proposition cited. Judge Johnston wrote that "given what this Court knows about generative artificial intelligence, the Court believes Defendants used it."
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction was imposed. The Court issued a caution: "Defendants are cautioned that the submission of false information including erroneous citations may result in sanctions." The motion for judgment on the pleadings was denied on the merits, with the negligence claim allowed to proceed.
Why does Sharky's Sports Bar v. Village of Mt. Morris, Illinois matter for law firms using AI?
Sharky’s illustrates the warning shot judges are increasingly willing to fire before reaching for Rule 11. The order names no attorney and imposes no fee, but the published rebuke is a permanent feature of the docket and a citable signal to opposing counsel and malpractice carriers that the firm filed a brief with citations the court believes were generated by AI without verification. For a small firm, the reputational exposure from a paragraph like this can outlast the underlying litigation.
Sources
Primary 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.