US | United States Court of Appeals for the Seventh Circuit
Docket: No. 25-1251 • appellate
2026-01-21
SOLOMON A. JONES v. KANKAKEE COUNTY SHERIFF’S DEPARTMENT, et al. — No. 25-1251 (Decided January 21, 2026)
Unknown / Not Disclosed (suspected) no_human_verification; fabricated_or_misattributed_quotations; suspected_generative_ai_use; pro_se_filing
I. Executive Summary
The Seventh Circuit addressed apparent “hallucinated” quotations attributed to real cases in a pro se appellant’s reply brief and discussed risks of AI-assisted drafting by self-represented litigants. The panel said it was skeptical of the litigant’s denial of AI use but found no reason to believe the misstatements were knowing or intentional. It therefore declined to impose sanctions and instead issued cautionary guidance emphasizing accuracy and honesty in filings. Separately, the panel vacated the district court’s Younger stay and remanded due to an intervening change in the related state proceeding.
II. Conduct Analysis
A pro se litigant filed an appellate reply brief containing quotations that do not appear in the cited decisions; the court considered whether AI-assisted drafting contributed to the errors and addressed verification expectations for unrepresented parties.
III. Legal Foundations
Fed. R. Civ. P. 11(b)(2)-(3) (certification of legal/factual contentions); Fed. R. App. P. 38 (sanctions for frivolous appeals, referenced); Younger v. Harris, 401 U.S. 37 (abstention doctrine addressed in disposition)
IV. Key Facts
The court identified non-existent/misattributed quotations in the reply brief and issued a show-cause inquiry; in the merits disposition it stated it remained skeptical about the denial of AI use but found no basis to infer intentional deception and highlighted differing expectations for pro se litigants.
V. Consequences & Sanction
District court stay vacated; case remanded for further proceedings; no sanctions imposed for the AI-related filing issues; appellate guidance issued on accuracy obligations for AI-assisted filings.