The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.
Docket entry 137, 30 September 2026 · source · PDF · 1 pages
Docket text. MINUTE entry before the Honorable Steven C. Seeger: Plaintiffs' motion to strike Defendant Peacock's brief in support of the motion to dismiss (Dckt. No. 24 ) is hereby granted. Defendant's brief is stricken because it contains hallucinated citations, courtesy of AI. Mailed notice. (jjr, ) (Entered: 09/30/2026)
[24]) is hereby granted. Defendant's brief is stricken because it contains hallucinated citations, courtesy of AI. Mailed notice.
Docket entry 44, 13 June 2025 · source · PDF · 66 pages
Docket text. RESPONSE by Corina Peacockin Opposition to MOTION by Plaintiffs Advocate Aurora Health, Inc., Advocate Health Care Network to strike First MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Corina Peacock 23 (Plaintiffs' Notification of Non-Existent Lega 24 (Schmitz, Abigail) (Entered: 06/13/2025)
In Mid Cent., this Court opted for sanctions because counsel violated Rule 11 on at least three (3) separate occasions. In numerous other cases, the Court imposed sanctions when the attorney “knowingly” used hallucinated or non-existent cases into a pleading. See United States v.
Here, Defendants’ counsel did not knowingly or willfully submit hallucinated or nonexistent citations into the record; this has not happened before; and the majority of the citations in the brief, while miscited, address on point, the legal issue at hand.
Case: 1:25-cv-02419 Document #: 44 Filed: 06/13/25 Page 10 of 66 PageID #:548 11 4. I am aware that the use of Generative Artificial Intelligence (“AI”) has the proclivity to generate nonexistent case law, mis-cite case law, cite non-citable (unpublished) case, and create hallucinated cases. 5.
Docket entry 24, 23 May 2025 · source · PDF · 6 pages
Docket text. MOTION by Plaintiffs Advocate Aurora Health, Inc., Advocate Health Care Network to strike First MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Corina Peacock 23 (Plaintiffs' Notification of Non-Existent Legal Authority and Rule 12(f) Motion to Strike) (Bina, Mark) (Entered: 05/23/2025)
Steven C. Seeger PLAINTIFFS’ NOTIFICATION OF NON-EXISTENT LEGAL AUTHORITY AND RULE 12(F) MOTION TO STRIKE Plaintiffs, Advocate Health Care Network (“Advocate Illinois”) and Advocate Aurora Health, Inc. (“AAH”) (together “Advocate Health” or “Plaintiffs”), by their attorneys, Quarles & Brady LLP, hereby notify the Court of citations to false and “hallucinated” legal authorities in Defendant Corina Peacock’s (“Peacock”) Motion to Dismiss (the “Motion”).
(internal citation omitted). “It is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs.” Sanders v. United States, 24-CV-1301, 2025 WL 957666, at *4 (Fed.
Case: 1:25-cv-02419 Document #: 24 Filed: 05/23/25 Page 1 of 6 PageID #:265 2 Advocate Health submits this Notification and Motion to Strike because , on information and belief, it appears that Defendant Peacock employed generative AI in drafting her Motion. Dkt. #23.1 The Motion contains several instances of what appear to be AI -generated hallucinations, constituting incongruous arguments, fabricated citations, and false quotations of legal authority. The Motion is also procedurally improper as Defendant Peacock fully answered the Complaint before moving to dismiss.
III. THE FALSE CITATIONS AND HALLUCINATIONS Defendants filed their combined Answer on May 16, 2025. See Dkt. #22.
2003): “This requires ‘evidence of personal direction or active participation in the tortious conduct.’” Mot. at 8. However, once again, this quotation does not exist in that opinion. These citation errors and false quotations are consistent with what other courts have observed in dealing with generative AI hallucinations.
3 Peacock cites this case for the quotation: “[t]o hold a corporate officer personally liable for trademark infringement, a plaintiff must allege that the officer ‘personally participates in or directs the tortious acts.’” Mot. at 8. This quoted language does not appear in the opinion and the cited page does not exist. T his case actually cuts against Peacock’s arguments, because there, the court found the plaintiff “sufficiently pleaded the ‘special 3 The correct citation is: Chinese Consol.
2d at 877, 885- 86. In the actual opinion, t he bolded language does not exist. The Motion may contain other problematic citations or quotations.
IV. REQUEST FOR RELIEF Advocate Health requests that the Court strike Peacock’s Motion in its entirety so that it need not spend further resources in having to respond to a procedurally improper document containing non-existent legal authorities and quotations. Advocate Health defers to the Court as to whether sanction s may be warranted for this conduct.