7th Circuit warns pro se litigants about AI-driven misquotes in appellate filings

AI Model: Unspecified generative AI tool

I. Executive Summary

The U.S. Court of Appeals for the Seventh Circuit issued an opinion addressing concerns that a self-represented appellant’s brief contained quotations that did not appear in cited decisions, which the panel said had hallmarks of an AI “hallucination.” The court expressed skepticism about the litigant’s denial of AI use but declined to impose sanctions, emphasizing the distinct analysis for pro se parties. The opinion nonetheless underscored that accuracy and honesty obligations apply to unrepresented parties and referenced Rule 11-style reasonable inquiry principles.

II. Key Facts

Seventh Circuit opinion in Jones v. Kankakee County Sheriff’s Department (No. 25-1251) decided January 21, 2026.• Panel identified quotations attributed to two cases that were not present in those decisions and discussed AI “hallucinations.”• Court issued observations aimed at pro se use of AI tools; declined sanctions due to lack of evidence of knowing/intentional misrepresentation and limited capacity to verify citations.• Opinion emphasized that all litigants must avoid misrepresentations and linked obligations to “reasonable inquiry” standards (Rule 11 framing).• Case was vacated/remanded on other procedural grounds unrelated to AI use.

III. Regulatory & Ethical Implications

Illustrates emerging appellate-level guidance that courts may treat AI-related inaccuracies by pro se litigants with some leniency while still signaling enforceable minimum standards; provides a doctrinal hook (reasonable inquiry / certification principles) that can be leveraged in future motions against represented parties and informs court-led policy development on AI-influenced filings.

IV. Media Coverage & Sources

No external sources linked.