Cook County, Ill. (Chancery): Calendar 9 Courtroom Procedures, AI Provision (Hon. Cecilia…
Hon. Cecilia A. Horan · Circuit Court of Cook County, County Department, Chancery Division, Calendar 9
Verified September 30, 2026
- Citation
- Calendar 9 Courtroom Procedures, AI Provision (Hon. Cecilia A. Horan, Cook County)
- Order date
- April 5, 2024
Status and former requirement
No longer in force (rescinded); this order does not state current filing practice. While it was operative it required: Any use of large language model artificial intelligence (such as ChatGPT) in the preparation of briefs or other submissions to the Court had to be indicated in the caption on the motion, brief or other filing with the Court (text effective April 5, 2024).
What the order required while in force
- Any use of large language model artificial intelligence (such as ChatGPT) in the preparation of briefs or other submissions to the Court had to be indicated in the caption on the motion, brief or other filing with the Court (text effective April 5, 2024).
- 'Failure to do so may result in sanctions.'
- Text effective June 30, 2025, reversing the rule: 'It is not necessary to disclose to the Court any use of large language model artificial intelligence, such as ChatGPT, in the preparation of briefs or other submissions to the Court. You are responsible for any and all content in your briefs or other submissions, including those prepared with the use of artificial intelligence.'
- Current text: none. Judge Horan's Calendar 9 order effective June 8, 2026 has no AI section, and Calendar 9 is now assigned to Judge John H. Ehrlich, whose August 27, 2026 standing order supersedes all prior standing orders.
Practice areas: state civil, state commercial
No longer in force
Judge Horan withdrew this rule in two steps. Her Calendar 9 standing order effective June 30, 2025 reversed it outright: “It is not necessary to disclose to the Court any use of large language model artificial intelligence, such as ChatGPT, in the preparation of briefs or other submissions to the Court. You are responsible for any and all content in your briefs or other submissions, including those prepared with the use of artificial intelligence.” Her order effective June 8, 2026 dropped the AI section altogether. Calendar 9 is now assigned to Judge John H. Ehrlich, whose standing order effective August 27, 2026 supersedes all prior Calendar 9 standing orders. Everything below describes the April 5, 2024 rule while it was operative.
What the rule required
Judge Horan’s Calendar 9 procedures (effective April 5, 2024) imposed a single operational requirement: any use of large language model AI (the rule named ChatGPT) in preparing briefs or other submissions had to be indicated in the caption of the filing. The disclosure went in the caption itself, not a separate certificate. Failure to disclose could result in sanctions.
Why the reversal matters
The June 2025 text is an unusually direct statement of a court withdrawing a disclosure mandate: the same judge who had required caption disclosure replaced it with a statement that disclosure is “not necessary,” keeping only the filer’s responsibility for content.
R&G data correction
R&G’s AI Court Order Tracker labels this entry simply “Horan.” Some readings of R&G’s tracker have conflated this with Judge Joan H. Lefkow, who is an N.D. Ill. (federal) judge in a different court entirely. The actual judge is Hon. Cecilia A. Horan of the Circuit Court of Cook County.
Quotable language (text effective April 5, 2024)
“Any use of large language model artificial intelligence, such as ChatGPT, in the preparation of briefs or other submissions to the Court must be indicated in the caption on the motion, brief or other filing with the Court.”
“Failure to do so may result in sanctions.”
Primary source
Calendar 9 standing order, effective April 5, 2024 (PDF)
Order effective June 30, 2025 (PDF); order effective June 8, 2026 (PDF)
How this order changed
Dated record of this order's own lifecycle. Where it was amended or withdrawn, the badge shows its standing after that step.
- activeCalendar 9 standing order takes effect with Section XIII: any use of large language model AI must be indicated in the caption; failure may result in sanctions. source
- amendedA replacement Calendar 9 standing order, effective June 30, 2025, reverses Section XIII: it is 'not necessary to disclose' large language model AI use, and filers remain responsible for all content. source
- rescindedJudge Horan's next Calendar 9 standing order, effective June 8, 2026, omits the AI section entirely. source
- Calendar 9 is reassigned to Judge John H. Ehrlich, whose standing order supersedes all prior standing orders and adds its own AI provision. source