Was Rhyu v. Frost sanctioned over AI-generated citations?

Rhyu v. Frost (CA Illinois (1d), September 29, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Dismissal with prejudice affirmed; trial court had cited reliance on AI-hallucinated cases as an additional reason to deny leave to amend; no appellate sanction imposed. No monetary penalty in this order.

Which AI tool was involved in Rhyu v. Frost?

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

September 29, 2026 · AI sanctions database

Rhyu v. Frost

Rhyu v. Frost 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 (1d)
Date: September 29, 2026
Party: Pro Se Litigant
AI tool: Not identified in the order
Outcome: Dismissal with prejudice affirmed; trial court had cited reliance on AI-hallucinated cases as an additional reason to deny leave to amend; no appellate sanction imposed
Penalty: No monetary penalty in this order.

Dismissal

What the record shows

The Appellate Court of Illinois, First District, affirmed the dismissal with prejudice of a self-represented buyer's real estate claims. The trial court had found that one citation in her verified complaint and eight in her response to the motions to dismiss did not exist, called them "just a few" of the citations it could not verify, and named her "heavy reliance on AI-hallucinated cases" as an additional reason to deny further amendment. Both defendants had reported in reply briefs that they could not locate multiple cited cases. The appellate court affirmed on briefing deficiencies and an incomplete record, and imposed no separate sanction.

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 ↗ · CourtListener record ↗

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 (1d)

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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