Illinois · state appellate court · 2026

Rhyu v. Frost

Appellate Court of Illinois, 29 September 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Ill. App. Ct.

  1. Court. Appellate Court of IllinoisCOURT
  2. Level. state appellate courtLEVEL
  3. Date. 29 September 2026DATED
  4. Docket. No. 1-25-2257DOCKET
  5. Reporter. 2026 IL App (1st) 252257CITE
  6. Documents. one document, 4 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 29 September 2026 · source · PDF · 12 pages

Frost pointed out that, within “the first two pages” of plaintiff’s argument section, eight of the cases that plaintiff cited purportedly in support of her argument w ere either nonexistent or completely unsupportive.

The court initially found that since plaintiff merely repeated many of the defects from her original complaint in her verified complaint, “[a] second amendment is unlikely 1-25-2257 6 to correct this, especially as the current pleading is verified.” The court then added, “An additional reason to dismiss plaintiff ’s illogical and improperly pled claims is plaintiff ’s heavy reliance on Al-hallucinated cases .” The court said that one alleged case citation in plaintiff’s verified complaint and eight alleged citations in her response did not exist.

The court criticized plaintiff’s pleadings as “bear[ing] no relationship to the agreements” underlying her claims and found that plaintiff had “brazenly” misstated or fabricated the law, and lead defendants and the court on a “wild goose chase.” The court concluded that plaintiff’s multiple pleading deficiencies did not warrant a further opportunity to amend, ordering plaintiff’s complaint dismissed with prejudice. ¶ 17 On September 25, 2025, plaintiff filed a “motion to reconsider and vacate dismissal with prejudice *** and to set a schedule for filing a second amended complaint.” 5 Plaintiff did not address alleged use of AI -hallucinated cases; rather, she argued in substance that the […]

1-25-2257 7 meet the standard for reconsideration under Illinois law and “several counts of the second amended complaint” are not curable. The court further referenced the “AI Hallucinated cases” in plaintiff’s briefing on defendants’ motions to dismiss. This appeal follows. ¶ 19 ANALYSIS ¶ 20 On appeal, plaintiff contends that the trial court erred in (1) granting defendants’ motions to dismiss with prejudice and (2) denying her motion to reconsider.

What the text mentions

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More from Appellate Court of Illinois, from Illinois, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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