Was In re S.M., a Minor sanctioned over AI-generated citations?

In re S.M., a Minor (CA Illinois, August 7, 2025) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Monetary penalty: $1,000 to the appellate court clerk; ARDC referral. $1,000 in monetary penalties.

Which AI tool was involved in In re S.M., a Minor?

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

August 7, 2025 · AI sanctions database

In re S.M., a Minor

In re S.M., a Minor 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: August 7, 2025
Party: Lawyer
AI tool: Not identified in the order
Outcome: Monetary penalty: $1,000 to the appellate court clerk; ARDC referral
Penalty: $1,000 in monetary penalties.

FineBar referralProfessional sanction

What the record shows

The court found that all four case citations in appellate counsel's brief were invalid, including two cases ('In re M.M.' and 'In re A.P.') that appear to be fictitious, and that counsel's show-cause explanations were disingenuous and misleading. Under Illinois Supreme Court Rule 375 the court ordered counsel to pay $1,000 to the clerk of the Fourth District Appellate Court and directed that a copy of the decision be sent to the Illinois Attorney Registration and Disciplinary Commission (ARDC).

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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