Jordan v. Chicago Housing Authority

Jordan v. Chicago Housing Authority, No. 2022L 000095 (Ill. Cir. Ct., Cook County, Law Division), sanctions order entered December 5, 2025. State trial court. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-115-jordan-v-chicago-housing-authority.pdf`.

Attorney Danielle Malaty, then a partner at Goldberg Segalla LLP, used ChatGPT for research and drafting on three defense motions, producing fictitious authority including the nonexistent Mack v. Anderson case, and never verified the citations, in violation of her own firm's AI policy. Lead partner Larry Mason signed the post-trial motion after only a light edit, never read the cases, and repeatedly asserted to the court that the problem was limited to a single case even though plaintiffs later identified fourteen misrepresentations of authority, plus false quotations and a second nonexistent case (First Chicago Bank v. Brandwein) in other motions.

Illinois Supreme Court Rule 137 and Rules of Professional Conduct 1.1, 3.3, and 5.1. Sanctions: Mason ordered to pay $10,000 to plaintiffs' counsel (Rapoport Sims Perry & VanOverloop PC) within 45 days; Goldberg Segalla LLP ordered to pay $49,500 to the same firm within 45 days; two sections of the post-trial motion (III.B.(3) at pages 25-26 and V at pages 31-37) stricken, including all claims of error tied to the fabricated authorities. Sanctions were denied as to Malaty, William O'Connell, and Daniel Woods. The order notes Malaty had been sanctioned $10 in Calderon v. Dynamic Manufacturing on July 16, 2025, the day before the July 17, 2025 hearing in this case, for the same ChatGPT conduct.

(a) Signing partners must read the cases in the brief they sign, especially any favorable case on the central disputed issue. (b) Once one hallucination is found, audit everything that attorney drafted before assuring the court it was "only one case." (c) A firm AI policy only works if attorneys follow it and the firm verifies acknowledgment; Malaty's violation went undetected through multiple layers of review.