N.D. Ill.: Standing Order on Artificial Intelligence (Judge Iain D. Johnston, N.D. Ill.)
Judge Iain D. Johnston · U.S. District Court for the Northern District of Illinois
Verified September 30, 2026
- Citation
- Standing Order on Artificial Intelligence (Judge Iain D. Johnston, N.D. Ill.)
- Order date
- December 19, 2023
Summary
Anyone (counsel and unrepresented parties alike) using AI in connection with the filing of a pleading, motion, or paper in this Court or in serving discovery must comply with Federal Rule of Civil Procedure 11(b).
What does the order require?
- Anyone (counsel and unrepresented parties alike) using AI in connection with the filing of a pleading, motion, or paper in this Court or in serving discovery must comply with Federal Rule of Civil Procedure 11(b).
- Anyone using AI must comply with Federal Rule of Civil Procedure 26(g).
- Anyone using AI must comply with any other relevant rule, including any applicable ethical rule.
- The order references the Grossman / Grimm / Brown article in Judicature (2023) discussing whether AI disclosure is necessary.
Practice areas: federal civil
What the order requires
Judge Johnston’s standing order takes a Rule-11/26(g)-anchored approach. It does not require a separate disclosure declaration or AI certification. Instead, it reminds counsel and pro se litigants that existing Rule 11(b), Rule 26(g), and other relevant ethical rules apply to AI-prepared filings. Any verification obligation comes from Rule 11’s reasonable-inquiry duty rather than a chambers-specific mechanism, so this entry records the order as binding without an AI-specific verification facet (the same treatment as Judge Hodge’s order).
Johnston’s order parallels Judge Hodge’s E.D. Pa. order and Judge Robinson’s S.D. Cal. order in framing AI use as a Rule 11 problem rather than a disclosure problem. The doctrinal point is that fabricated AI citations violate Rule 11 even absent an AI-specific rule, because the verification obligation is the operative duty regardless of tooling.
The order references the Grossman / Grimm / Brown article in Judicature (2023), which is the canonical academic discussion of AI disclosure regimes; the citation is unusual for a chambers standing order and signals that Johnston tracked the academic debate when crafting his rule.
Continued enforcement
In Halpern v. Federal Reserve Bank of New York (N.D. Ill. Dec. 17, 2025), Judge Johnston found that a quotation attributed to a real case did not exist, said it was likely “hallucinated by Artificial Intelligence,” and admonished the pro se plaintiff that he “has subjected himself to the possibility of sanctions.” That order does not cite this standing order.
Quotable language
“Anyone, counsel and unrepresented parties alike, using AI in connection with the filing of a pleading, motion, or paper in this Court or the serving/delivering of a request, response, or objection to discovery must comply with Rule 11(b) and Rule 26(g) of the Federal Rules of Civil Procedure, and any other relevant rule, including any applicable ethical rule.”
Primary source
Judge Johnston’s Case Management Procedures (AI Standing Order), ilnd.uscourts.gov