Williams v. Chicago Board of Education
U.S. District Court, Northern District of Illinois, Eastern Division · N.D. Ill. · Illinois bar guidance
Verified May 5, 2026
- Citation
- Williams v. Chicago Board of Education, Nos. 1:24-cv-11729 & 1:25-cv-06644 (N.D. Ill. Mar. 30, 2026)
- Decided
- March 30, 2026
Summary
Plaintiff Shohn Williams's response brief, filed by his counsel, contained two wholesale fabricated quotations attributed to Seventh Circuit decisions: a non-existent quote attributed to EEOC v. University of Chicago Hospitals, 276 F.3d 326, 332 (7th Cir. 2002), and another attributed to Doe v. Village of Arlington Heights, 782 F.3d 911, 917 (7th Cir. 2015). The brief also cited Engquist v. Oregon Department of Agriculture, 553 U.S. 591 (2008), for a proposition that is the opposite of what the Supreme Court actually held. Judge Edmond E. Chang flagged the fabrications as likely hallucinated quotations from generative AI.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction imposed. Judge Chang ordered Williams's counsel to file a Statement of Explanation by April 13, 2026, addressing how the two non-existent quotations and the misrepresented Engquist citation came to appear in the brief, and whether the same source produced other similar problems throughout the filing.
Why does Williams v. Chicago Board of Education matter for law firms using AI?
Williams illustrates how AI hallucinations now surface routinely in employment-litigation briefing in federal district court, not just in the headline cases. Judge Chang’s order stops short of formal Rule 11 sanctions but compels plaintiff’s counsel to account on the record for fabricated quotations and a reversed-meaning citation, the kind of incident that a malpractice carrier will treat as a reportable circumstance regardless of whether the court ultimately imposes a fine.
Sources
Primary sources
Further reading
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
- Justia (legal aggregator)
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.