Which AI tool was involved in In re S.A., D.H., and B.M., Minors?

The order in In re S.A., D.H., and B.M., Minors does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

December 29, 2025 · AI sanctions database

In re S.A., D.H., and B.M., Minors

In re S.A., D.H., and B.M., Minors 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: CA Illinois
Date: December 29, 2025
Party: Pro Se Litigant
AI tool: Not identified in the order
Outcome: No sanction; arguments addressed on merits
Penalty: No monetary penalty in this order.

What the record shows

The appellate court observed that the pro se respondent's brief cited real cases accompanied by fictitious quotes and holdings, language it noted was likely produced by artificial intelligence. Because termination of parental rights implicates a fundamental liberty interest, the court declined to strike the brief and instead addressed the arguments on their merits.

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 · CA 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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