Case D-63 · AI Sanctions Case Tracker

D'Angelo v. Vaught

Circuit Court of the First Judicial Circuit, Williamson County, Illinois, April 2, 2025

The case

Lynn D'Angelo v. Mark Vaught and Timothy Vaught, Circuit Court of the First Judicial Circuit, Williamson County, Illinois, filed April 2, 2025, No. 21-CH-29 (Associate Judge Jeffrey A. Goffinet). Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-63-dangelo-v-vaught.pdf` (4-page scanned Order Imposing Sanctions).

What happened

Attorney Scott Walker of SK Walker Law, LLC twice cited a nonexistent case, "Hauter v. DeWitt, 73 Ill.App. 3d 263," including with a purported quotation from it, in responses to motions to dismiss. Walker admitted that he uploaded his draft to "Archie," a closed AI developed by Smokeball, to "enhance text, improve the documents readability, and expand its content," at which point Archie "inadvertently altered or incorrectly replaced" some case citations. The court found this explanation did not account for the October 2024 filing, which actually quoted the fake case, and held that counsel is accountable for his final work product.

The rule and the sanction

Violation of Illinois Supreme Court Rule 137 (certification by signature that filings are well grounded in fact and warranted by existing law) and the Illinois Supreme Court's Policy on Artificial Intelligence (effective January 1, 2025). The court, acting on its own initiative, sanctioned Walker $2,000 ($1,000 for each citation), to be donated to the Lawyers Assistance Program within 30 days, with a receipt submitted to the court within 7 days of receipt. An Illinois State Bar Association newsletter article (John Holevas, "A Cautionary Tale in the Use of AI in Pleadings," June 2025) recounting Judge Goffinet's Allerton Conference remarks reports that he also reported Walker to the ARDC; the held order makes no mention of a referral, and this entry's classification rests on the order. Source URL: the primary PDF (Charlotin documents archive: /documents/609/Dangelo_v._Vaught_USA_2_April_2025.pdf, https://www.damiencharlotin.com/documents/609/Dangelo_v._Vaught_USA_2_April_2025.pdf).

How it could have been avoided

Understand what an AI editing tool does to your text before using it on court filings; enhancement tools can silently replace citations. Proofread the final version after any AI processing. When the court asks you to produce a cited case, produce it or admit the error promptly instead of substituting unrelated authority.

Sources