Was DeVore v. McCombie sanctioned over AI-generated citations?

DeVore v. McCombie (N.D. Illinois, May 11, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: No penalty reported (concern noted); motion to dismiss granted. No monetary penalty in this order.

Which AI tool was involved in DeVore v. McCombie?

The order in DeVore v. McCombie does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

May 11, 2026 · AI sanctions database

DeVore v. McCombie

DeVore v. McCombie is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: N.D. Illinois
Date: May 11, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: No penalty reported (concern noted); motion to dismiss granted
Penalty: No monetary penalty in this order.

What the record shows

In granting the defendant's motion to dismiss, the court noted with concern that defendant appeared to cite a case (Beecham v. City of Anniston) that the court was unable to locate, while another cited case was real. The court flagged the apparent non-existent citation but reported no sanction in the provided text.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · N.D. Illinois

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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