In an era where artificial intelligence promises to revolutionize everything from writing to research, some people are asking: "Why pay for a lawyer when AI can do it for free?" A recent Illinois appellate court decision provides a stark answer to that question—and it's an expensive one.

When Cutting Costs Becomes Costly

In BKA Holdings, LLC v. Sam (2025 IL App (2d) 250160-U), decided just yesterday, Robert and Karen Sam found themselves facing eviction from their rental property. Rather than hire an attorney, they chose to represent themselves and rely on artificial intelligence to help craft their legal arguments.

The results were disastrous.

Not only did the Sams lose their appeal, but the Illinois Appellate Court imposed sanctions against them for citing four completely fabricated court cases generated by AI. The court struck their entire reply brief and ordered them to pay the opposing party's attorney fees and costs for having to research and respond to these non-existent cases.

How AI "Hallucinations" Became a Legal Nightmare

The term "hallucination" in AI refers to when these systems confidently generate information that simply doesn't exist. In the Sams' case, their AI tool created what appeared to be legitimate court citations, complete with case names, court references, and legal holdings. The problem? None of these cases were real.

The appellate court was not amused. As they noted in their decision:

"Flagrant and unprincipled use of AI without ensuring the accuracy of the generated response 'is an abuse of the adversary system' as it wastes court resources that would be better spent elsewhere."

The court referenced another recent case where an attorney was fined $1,000, ordered to disgorge his fees, and referred to the disciplinary commission for similar AI misconduct. Even though the Sams were representing themselves, the court found no excuse for their "careless reliance on AI."

The Real Cost of "Free" Legal Help

Here's the irony: the Sams thought they were saving money by avoiding attorney fees. Instead, their DIY approach with AI assistance likely cost them far more than hiring a lawyer would have in the first place. They now face:

• Payment of the opposing party's attorney fees for researching fake cases
• Additional court costs and sanctions
• The time and stress of dealing with these consequences
• Most importantly, they still lost their home

Why Professional Legal Representation Matters

This case illustrates several critical points about legal representation:

Legal Research Requires Verification

Experienced attorneys know how to verify case citations, understand legal databases, and recognize when something doesn't look right. AI tools, no matter how sophisticated, can generate convincing-sounding but completely false information.

Understanding Procedure and Strategy

The Sams also failed to follow basic appellate rules, including proper citation formats and standards of review. These procedural errors can doom an otherwise valid legal argument.

Knowing When You're Outmatched

Landlord-tenant law involves complex statutes, local ordinances, and case law. What seems straightforward to a layperson often involves nuanced legal principles that require professional expertise.

The Stakes Are Real

In the Sams' case, they lost their home and now owe additional money in sanctions. Some legal mistakes can't be undone.

AI as a Tool, Not a Replacement

This isn't to say that AI has no place in legal practice. Many law firms, including sophisticated practices, use AI tools to assist with research, document review, and case preparation. The key difference is that these tools are used by trained professionals who understand their limitations and know how to verify the output.

The Illinois Supreme Court has issued guidance permitting AI use in legal practice, but with a crucial caveat: "All users must thoroughly review AI-generated content before submitting it in any court proceeding to ensure accuracy and compliance with legal and ethical obligations."

The Bottom Line

We understand that legal fees can be a concern, especially when facing financial stress like an eviction. However, as the Sams learned, the cost of inadequate representation—or misplaced reliance on AI—can far exceed the investment in professional legal help.

At CTM Legal Group, we've seen countless situations where early intervention by an experienced attorney could have prevented much larger problems down the road. Whether you're facing eviction, dealing with landlord-tenant disputes, or navigating other legal challenges, the expertise of a qualified attorney often proves to be not just valuable, but cost-effective in the long run.