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U.S. District Court sanctions attorney $1,000 for using AI-generated hallucinations in ADA lawsuit

Bot Mutiny | September 5, 2026

The U.S. District Court for the Central District of Illinois has ordered attorney David Baldemar Reyes to pay a $1,000 fine after he filed a motion containing fake legal citations generated by artificial intelligence. In an order filed September 2, 2026, the court also required Reyes to report the incident to the Illinois Attorney Registration and Disciplinary Commission. The case, Cole v. Amain.com, Inc. (Case No. 4:25-cv-04217-SLD-RLH), began as a lawsuit alleging violations of Title III of the Americans with Disabilities Act. According to documents first reported by CourtListener, the plaintiff, a visually impaired individual named Morgan Cole, claimed he could not navigate the defendant's website. The defendant, Hobby Town Unlimited, Inc., never appeared in the case. When Reyes moved for default judgment on January 27, 2026, the court noticed the motion contained several hallucinated citations. The court identified these as classic indicators of unverified AI usage. ## A pattern of fictitious filings

Judge Sara Darrow noted that this wasn't the first time Reyes had been caught using fake citations. The court pointed to a similar incident in the Eastern District of Wisconsin, Hippe v. Retention Brands, LLC, where Reyes was ordered to show cause for using the exact same improper citations in a different motion for default judgment. Reyes admitted in his response to the Illinois court that he prepared a template using AI, which inserted the hallucinated citations. He stated that he accepted full responsibility and had implemented corrective measures. He argued for minimal sanctions, citing recent Seventh Circuit history. The court rejected the idea that good faith or the novelty of AI served as a defense. Under Federal Rule of Civil Procedure 11, the court found Reyes's conduct was not objectively reasonable. The ruling states that the inclusion of fictitious cases is obviously inconsistent with the standards of conduct expected from attorneys. ## Mandated reporting to disciplinary board

The $1,000 fine is intended to deter similar conduct by others. The court emphasized that the concern lies with trained lawyers failing to check the accuracy of legal citations and quotations in their filings. Because Reyes had engaged in similar conduct in other litigation, the court determined that a monetary penalty alone was not sufficient. By ordering the attorney to send the court's order to the Illinois ARDC, the court ensured that his professional licensing body is made aware of the AI-driven misrepresentations. The full order and docket information can be accessed at CourtListener. Reyes had requested an extension of time to respond to the initial show cause order to retain his own attorney. Despite these efforts, the court found the violation of Rule 11(b) clear. The primary document, ECF No. 33, serves as a formal record of the sanctions imposed for the misuse of generative software in federal court.