Bill Tasch | February 2026

A few months ago I wrote about the dangers of using AI as a substitute for an actual lawyer. That post featured an Illinois appellate case where unrepresented litigants submitted court briefs filled with AI-generated citations to cases that simply did not exist—so-called "hallucinations" from the AI—and paid a steep price for it. Cases involving AI-generated legal filings packed with fictitious citations keep coming. And with each new decision, it's becoming clear that courts are losing what little patience they had for this.

The Pletcher Case: A Police Officer's Disability Pension Claim Goes Up in Smoke

The latest cautionary tale comes from the Illinois Appellate Court, Second District, decided in November 2025: Pletcher v. Village of Libertyville Police Pension Board (2025 IL App (2d) 240416-U).

Bryan Pletcher, a Libertyville police officer, applied for a not-on-duty disability pension based on serious heart conditions. It appeared to be a legitimate claim with real medical issues at stake—his pension, his financial future. The Pension Board denied his application largely on the grounds that Pletcher's cardiac problems were caused by his own repeated refusal to take prescribed medications and follow his doctors' advice. Three physicians retained by the Board all agreed: had Pletcher been medication-compliant, he would not have developed the condition at all. Pletcher had the opportunity to introduce his own evidence to rebut this, but did not do so.

Pletcher then appealed, and he did so without a lawyer. Under Illinois law, this afforded him no special leniency. Pro se litigants — people who represent themselves without an attorney — are held to exactly the same standards as represented parties. They must follow the same rules, meet the same deadlines, and comply with the same procedural requirements. Illinois courts have applied this principle consistently for decades. "I didn't know" is not a defense.

When the trial court reviewed the Board's decision, the judge stated that he thought Pletcher had a strong case on the merits—but that because Pletcher had never introduced any supporting evidence into the record at the pension board hearing level, the court's hands were tied. He affirmed the Board's denial.

Pletcher then appealed his case to the next level, the Illinois Appellate Court, where things got worse. In his appellate brief, Pletcher cited numerous cases that do not exist. Not obscure cases that are hard to find—cases that were simply made up. Whole cloth. The AI that generated his brief fabricated case names, citation numbers, court districts, and favorable-sounding legal holdings that would have been quite useful to Pletcher's argument, if only they were real.

Beyond the phantom cases, Pletcher also cited real cases but attributed to them holdings and quotes that appear nowhere in those decisions. A case about a firefighter's dislocated shoulder became authority for the principle that pension boards can't deny benefits to people who try-but-fail to comply with medical treatment. A case about a police officer's on-duty injury became a statement about non-compliance with treatment. And so on.

When the opposing party flagged these problems, Pletcher filed a motion to correct his citation errors. His motion also cited fake quotes and holdings. The court denied this motion, but did analyze these cases in its final decision. In its decision handed down November 24, 2025, the court spent five and a half pages methodically working through each fabricated case and fraudulent quote. The court tracked down the real cases Pletcher claimed to have intended to cite and demonstrated that those cases also did not support his arguments. One gets the sense that the justices were not enjoying the exercise.

At oral argument, Pletcher was contrite and accepted full responsibility for his errors. That candor, it turns out, was the smartest thing he did in the entire appeal. The court took note of it and declined to impose monetary sanctions — which could have included the opposing party's attorney's fees and costs. His honesty when confronted saved him real money.

It did not, however, save his case. The court struck his entire brief and dismissed the appeal.

This Is Becoming a Pattern

The Pletcher court cited a Fourth District case from 2025, In re Baby Boy, where an attorney—not a pro se litigant, but a licensed lawyer—was sanctioned for the same thing. That attorney was ordered to return his fees, fined $1,000, and referred to the Illinois Attorney Registration and Disciplinary Commission for professional discipline.

Courts have also drawn on the now-famous federal case Mata v. Avianca, Inc., in which a New York federal judge came down hard on attorneys who submitted briefs full of AI-generated fake citations. That decision sent shockwaves through the legal community in 2023 and established the template that courts have been following ever since.

The Illinois Supreme Court has issued a formal AI policy that permits the use of artificial intelligence in legal practice—but with an unambiguous requirement that all AI-generated content be thoroughly reviewed for accuracy before any court submission. Judges are now educated about how AI hallucinations work. They know what they're looking at. And they are not sympathetic.

AI Is an Essential Legal Tool. It Is Not a Lawyer.

Let me be direct about something, because I think it's important to say plainly: in my opinion, AI has become an indispensable part of practicing law at the highest level. These tools, used correctly, make us better, faster, and more thorough advocates for our clients.

But here is the critical distinction: we use AI as a tool. A skilled tool in experienced hands.

When a lawyer uses AI to assist with legal research, she then reads the actual cases. She checks the citations. She applies years of legal training to evaluate whether the AI's output makes sense, is applicable to the facts at hand, and accurately represents the law. The AI suggests; the lawyer decides.

When a non-lawyer uses AI to generate a legal brief and submits it without that verification layer, there is no backstop. There is no one with the training to recognize when the AI has invented a case or fabricated a quote. The output goes straight from the machine to the court—and judges notice.

Think of it this way: AI in legal practice is like a professional-grade power tool. A skilled craftsman uses a table saw to build beautiful, precise things — it makes him faster and better at his work. But the saw doesn't know what it's cutting. It doesn't know when something's gone wrong. It doesn't protect you from your own mistakes. In the hands of someone without the training to use it safely, it's not just ineffective — it's dangerous.

In court, the stakes are your pension, your home, your freedom, your money.

The Hard Truth About Going It Alone

Pletcher's situation is genuinely sympathetic. He had real medical issues, a real pension claim, and even convinced the state court judge that he had a strong case. But he represented himself at the pension board hearing and never put his supporting evidence into the record—evidence the trial court later said might have changed the outcome. By the time he got to the appellate court, it was too late to introduce that evidence. And then the AI hallucinations ended the appeal entirely.

The cost of not having a lawyer, in his case, was his disability pension.

We understand that people facing legal challenges often think about hiring an attorney the same way they think about other costs: can I handle this myself and save some money? Sometimes the answer is yes. But disability pension appeals are not simple matters. They have specific procedural requirements at every stage, tight deadlines, and rules about what evidence can and cannot be considered. A mistake at step one can be fatal to your case at step five, even if step five otherwise looks strong.

AI can help you understand a legal situation. It can explain concepts, summarize statutes, draft a letter (properly prompted). These are legitimate uses. But AI cannot evaluate your specific facts against a body of real case law. It cannot anticipate the procedural traps in your particular proceeding. It cannot sit across from a judge and make real-time adjustments. And, as we keep seeing, it will sometimes confidently invent cases that do not exist—and if you don't know enough to catch that, you'll submit those invented cases to a court.

Courts are not interested in explaining this to you after the fact. They will dismiss your case (even if they think it's a good case!). They will sanction you. And they will move on.

If You're Facing a Legal Matter, Talk to a Real Lawyer

At CTM Legal Group, we work with clients across a wide range of civil legal matters—including the kinds of cases where people are most tempted to go it alone because they're already under financial stress. We exist specifically to help people who might otherwise not have access to quality legal representation.

If you're facing a situation that feels too complex, too high-stakes, or too confusing to navigate alone, reach out. The consequences of the wrong decision are too high to leave to a machine.

Bill Tasch is Managing Partner and co-founder of CTM Legal Group.

LEGAL DISCLAIMER: This blog post is for informational purposes only and does not constitute legal advice. Do not rely on this information for legal decisions. CTM Legal Group is not your attorney unless we have a signed, written retainer agreement in place. For specific legal advice regarding your situation, please consult with a qualified attorney.