In re Baby Boy

In re Baby Boy, Nos. 4-24-1427, 4-24-1430 cons. (Ill. App. Ct., 4th Dist.), appellate opinion filed July 21, 2025 (2025 IL App (4th) 241427): the court's first issued opinion addressing AI-generated fictitious cases. Attorney: William T. Panichi of Springfield. Primary opinion: https://cases.justia.com/illinois/court-of-appeals-fourth-appellate-district/2025-4-24-1427.pdf?ts=1753201545 ; reported at: https://www.nprillinois.org/illinois/2025-08-25/in-court-hallucinations-can-overshadow-a-i-s-promise-in-closing-access-to-justice-gap ; https://www.beaconjournal.com/story/news/local/2025/07/31/springfield-attorney-william-panichi-fined-for-using-ai-to-write-briefs/85438608007/ ; https://www.wcia.com/news/sangamon-county/springfield-attorney-fined-for-using-ai-citing-nonexistent-cases/

Appointed November 4, 2024, to handle a parental-rights termination appeal, Panichi used AI to draft the brief and filed it with multiple nonexistent cases. The court found he "intentionally generated briefs using AI tools and intentionally did not check any of the citations that were generated by AI before filing the briefs," then "continued to mislead the court by maintaining that he properly cited two existing cases in his brief, even though the cases he identified in his response did not match the citations or even the case names of the cases cited in his briefs."

Violations of Illinois Supreme Court Rule 375, the Illinois Rules of Professional Conduct (2010), and the Illinois Supreme Court Policy on AI (which requires attorneys to remain "accountable for their final work product" and "thoroughly review AI-generated content before submitting it"). Sanctions: disgorgement of his $6,925.62 fee to the Sangamon County treasurer, a $1,000 fine to the Fourth District clerk (added "to help deter other attorneys"), and referral to the Attorney Registration and Disciplinary Commission (ARDC). The following month the Fourth District sanctioned Panichi in two further juvenile appeals for the same conduct, In re A.S., 2025 IL App (4th) 250298-U, and In re S.M., 2025 IL App (4th) 250277-U (Aug. 2025). [REPEAT ×3] The court found he was not "intentionally malicious" but "chose to ignore his professional obligations." Panichi, 56 years at the bar, said he would close his practice and surrender his license (his statement, published by WCIA: "I am working on closing out my practice appropriately and surrendering my license").

Being "extremely busy" is not a defense: build verification into the workflow (e.g., a rule that no brief is filed until every citation is confirmed in a citator). In appointed cases involving fundamental rights, the duty of diligence is at its highest. When the court questions your citations, answer accurately; misidentifying cases in your response is treated as misleading the court.

• Primary opinion: https://cases.justia.com/illinois/court-of-appeals-fourth-appellate-district/2025-4-24-1427.pdf?ts=1753201545
• nprillinois.org: https://www.nprillinois.org/illinois/2025-08-25/in-court-hallucinations-can-overshadow-a-i-s-promise-in-closing-access-to-justice-gap
• beaconjournal.com: https://www.beaconjournal.com/story/news/local/2025/07/31/springfield-attorney-william-panichi-fined-for-using-ai-to-write-briefs/85438608007/
• wcia.com: https://www.wcia.com/news/sangamon-county/springfield-attorney-fined-for-using-ai-citing-nonexistent-cases/