Seventh Circuit Sanctions Attorney for Filing Brief with AI Hallucinations

Seventh Circuit Sanctions Attorney for Filing Brief with AI Hallucinations

  Tuesday, June 02, 2026    Julie Tappendorf

---

The Seventh Circuit Court of Appeals sanctioned a lawyer for AI-generated hallucinations and other inaccuracies and errors in a brief filed with the Court in an immigration appeal. Perez-Castillo v. Todd Blanche.

An attorney filed an opening appellate brief with the Seventh Circuit on behalf of his client, who was appealing an immigration removal order. The Court denied the appeal on its merits in the opinion, and also addressed certain problems and irregularities the Court discovered in the appellate brief. The Court noted that about half of the cases cited in the court filing either did not exist or were falsely labeled as Seventh Circuit cases. The Court also noted that nearly every quotation in the filing could not be traced to a real case, a known hallmark of AI hallucinations. The Court also discovered false representations of the record in the filing, including statements about testimony and findings of the Immigration Judge. On order of the Court, the attorney responded that generative AI was used for the brief but he attributed that to another attorney (who had not filed an appearance in the case). The attorney admitted that he did not review the brief before filing it with the Court

The Court sanctioned the attorney who signed and filed the brief. The sanction (in the amount of $5,000) was based on a violation of the attorney rules of professional conduct rule 46, which authorizes a court to "suspend, disbar, or discipline a member of our bar ‘for conduct unbecoming a member of the bar.’” While the Court did not sanction the attorney who wrote the brief, it did admonish her that she must be cautious in ensuring any use of generative AI is in compliance with the attorney rules of professional conduct. The Court also referred the matter to the Attorney Registration and Disciplinary Commission (ARDC).

The Court ended its opinion with the following cautionary note to litigants and attorneys:

There is “little doubt that litigants and courts” will develop “sound and workable practices” governing AI usage in due time, but that point has not yet arrived. [citation omitted]. Briefs like those petitioner’s counsel submitted in this case are unacceptable and “result in confusion and time wasted” for this court. [citation omitted]. Members of this court’s bar must be exceedingly careful about outsourcing their work product. At all times, attorneys must follow both the Federal Rules of Appellate Procedure and this court’s Rules of Professional Conduct. If not, sanctions may follow.

Read More

School District Administrator Had Qualified Immunity in First Amendment Challenge

School District Administrator Had Qualified Immunity in First Amendment Challenge

  Monday, June 01, 2026    Julie Tappendorf

---

The Seventh Circuit Court of Appeals determined that a school district chief talent officer had qualified immunity in a First Amendment case brought by a school district employee who had been terminated for her social media posts in Hayes v. Board of Education.

A college administrator responsible for staffing student teachers in a school district was terminated by the school district for making disparaging comments on social media about the district. The comments included criticisms of the school district and its CEO, including circulating a petition calling for the district to investigate and report on racial inequities in the district. After her termination, she filed a lawsuit against the district's chief talent officer and against the board of education, claiming she was unlawfully retaliated against in violation of her First Amendment rights. The defendants filed a motion for summary judgment, claiming qualified immunity among other defenses, but the district court denied the motion. The defendants appealed to the Seventh Circuit Court of Appeals.

On appeal, the Seventh Circuit determined that the chief talent officer was entitled to qualified immunity against the First Amendment retaliation claim brought by the former employee. Specifically, the Court held that there was no prior caselaw that would put the chief talent officer on notice that his conduct in this case would violate the former employee's constitutional rights, one of the steps in a qualified immunity analysis. As a result, the former employee could not meet her burden to overcome the chief talent officer's qualified immunity defense.

Although the Seventh Circuit found that the chief talent officer had qualified immunity in the case, it allowed the former employee's First Amendment retaliation claim to proceed against the district.

Read More

Illinois General Assembly Spring 2026 End of Session Tracking

Illinois General Assembly Spring 2026 End of Session Tracking

  Friday, May 29, 2026    Julie Tappendorf

---

As the Illinois General Assembly draws closer to concluding its 2026 spring legislative session, there are a number of outstanding bills likely to be considered that would have a significant impact on local governments throughout Illinois. The General Assembly has been busy so far in the 2026 spring session passing a number of bills that will affect local government operations as well as a bill on regulating electric mobility devices. With three days left until the General Assembly recesses on May 31^st, the Governor’s BUILD Plan legislation, and other bills impacting local governments, may still be considered.

Below is a list of bills we’re tracking with updates on the bill’s status through May 28^th. 

Housing Legislation 

House Bill 5626: BUILD Plan Housing Omnibus Bill (First Reading; referred to House Rules Committee) 

Senate Bill 4060: Middle Housing & Statewide Standards (First Reading; referred to Senate Assignments Committee) 

Senate Bill 4061: Single-Stair Reform (First Reading; referred to Senate Assignments Committee) 

Senate Bill 4062: Statewide Impact Fee Calculation (First Reading; referred to Senate Assignments Committee)

 Senate Bill 4063: Third-Party Plan Review (First Reading; referred to Senate Assignments Committee) 

Senate Bill 4064: Parking Reform (First Reading; referred to Senate Assignments Committee) 

Senate Bill 4071: Accessory Dwelling Units (ADUs) (First Reading; referred to Senate Assignments Committee) 

Senate Bill 0331: Restock the Block Act (Second Reading; Senate Floor Amendment No. 1 introduced on May 21^st and recommended for adoption by the Senate Executive Committee) 

Senate Bill 0608: Federally Assisted Tenant Protection Act (Second Reading; Senate Floor Amendment No. 1 recommended for adoption by the Senate Executive Committee) 

Senate Bill 635: Faith-Based Housing and Mixed-Use By-Right Act (Second Reading; Senate Floor Amendment No.1 recommended for adoption by the Senate Executive Committee) 

House Bill 5765 / Senate Bill 4200: REAL Housing Act (Frist Reading; referred to House Rules Committee and Senate Assignments Committee) 

Other Legislation Affecting Local Governments 

House Bill 1429: Amendments to IL Homeless Bill of Rights (Second Reading; House Floor Amendment No. 1; House Floor Amendment No. 2 recommended for adoption by House Housing Committee; House Floor Amendment No. 3 recommended for approval by House Housing Committee; Bill and all House floor amendments re-referred to House Rules Committee)

House Bill 5513 / Senate Bill 4016: Power Act (First Reading; Bill re-referred to House Rules Committee and Senate Assignments Committee) 

House Bill 5326: Digital Library Protection Act (Passed House; House Floor Amendment No.1 and House Floor Amendment No. 2 adopted; First Reading in Senate; referred to Senate Assignments Committee) 

House Bill 4712: Amendments to Tax Increment Allocation Redevelopment Act (First Reading; Bill re-referred to House Rules Committee) 

Senate Bill 1796: Body Worn Camera FOIA Requests (Senate Committee Amendment No. 2 adopted; Passed Senate; Second Reading in House) 

Senate Bill 2715: OMA and FOIA Amendments: (Passed Senate; Second Reading in House; House Committee Amendment No. 1 adopted by House Executive Committee; House Floor Amendments No. 2, No. 3, No. 4, No. 5, No. 6, No. 7 recommended for adoption by House Executive Committee) 

House Bill 5784 / Senate Bill 20: Joint Omnibus CBD and Cannabis Regulatory Reform (First Reading in House and referred to House Rules Committee; First Reading in Senate; Senate Floor Amendment No. 1 referred to Senate Assignments Committee) 

Legislation Passed By Both Chambers 

Senate Bill 3336: Electric Mobility Devices (Passed both houses as of May 27, 2026; awaiting signature by Governor) 

Senate Bill 2836: Government Account Audits (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

Senate Bill 2826: IMRF Pension Benefits (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

Senate Bill 2769: Transfer of Funds Among Municipal Business District Tax Allocation Funds (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

Senate Bill 2102: Taxing District Budget and Appropriations Ordinance Filing (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

Senate Bill 638: Municipal Postemployment Benefit Trusts (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

Senate Bill 2761: Service Animals and In-Service ADA Trainings (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

Senate Bill 2913: Teacher Evaluation Plans (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

Senate Bill 2914: Procedure for Removing/Dismissing Teachers (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

Senate Bill 3361: Religious Hairstyles in Schools (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

House Bill 4375: School District Interfund Transfers (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

House Bill 5542: Park District Disconnection Petitions (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

House Bill 5166: Dissolution of Special Districts (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

House Bill 5167: Township Weed Cutting (Passed both houses as of May 21, 2026; awaiting signature by Governor) 

House Bill 4788: Cardiopulmonary Resuscitation Training Curriculum (Passed both houses as of May 20, 2026; awaiting signature from Governor) 

House Bill 4862: School Staff Mental Health Policies (Passed both houses as of May 20, 2026; awaiting signature from Governor) 

House Bill 4491: Amendment to Public Employee Disability Act (Passed both houses as of May 20, 2026; awaiting signature by Governor) 

House Bill 2137: Amendment to Governmental Account Audit Act (Passed both houses as of May 20, 2026; awaiting signature by Governor) 

House Bill 4397: School Psychologist Qualifications (Passed both houses as of May 19, 2026; awaiting signature by Governor) 

House Bill 3743: School District Handbook Railroad Safety Messaging (Passed both houses as of May 19, 2026; awaiting signature by Governor) 

House Bill 4137: Amendment to Education for Homeless Children Act (Passed both houses as of May 19, 2026; awaiting signature by Governor) 

House Bill 4361: Building Inspector Certifications (Passed both houses as of May 19, 2026; awaiting signature by Governor) 

House Bill 1353: Amendment to Volunteer Emergency Worker Job Protection Act (Passed both houses as of May 19, 2026; awaiting signature by Governor) 

House Bill 4541: Revised Uniform Unclaimed Property Act (Passed both houses as of May 14, 2026; awaiting signature by Governor) 

Post Authored by Tyler Smith, Ancel Glink

Read More

Police Search of Backpack During Arrest Was Lawful

Police Search of Backpack During Arrest Was Lawful

  Thursday, May 28, 2026    Julie Tappendorf

---

Federal appeals court rules against arrestee in challenge to police officer's seizure of backpack during arrest in U.S. v. Fillyaw. 

Local police officers executed a search warrant and arrested an individual in connection with an arson investigation. During the arrest (which took place in an apartment parking lot), police seized the arrestee's backpack and searched the contents, finding a loaded handgun and drugs. The arrestee filed a motion to suppress the evidence found in the backpack, arguing that the search violated his Fourth Amendment rights. The district court and Seventh Circuit Court of Appeals ruled in favor of the police, holding that police have the right to take custody of an arrestee's property and take inventory of that property when the arrest takes place in a public place.

Read More

Seventh Circuit Rejects Discrimination Claim by Candidate for Deputy Sheriff Position

Seventh Circuit Rejects Discrimination Claim by Candidate for Deputy Sheriff Position

  Wednesday, May 27, 2026    Julie Tappendorf

---

The Seventh Circuit Court of Appeals upheld a county sheriff office's decision not to hire a candidate for a deputy sheriff position, rejecting the candidate's racial discrimination claim in Burton v. Will County Sheriff's Merit Commission.

A candidate applied for a deputy sheriff position with a county sheriff's department. As part of the background check process, the county contacted the candidate's current employer, who stated that he was not a dependable employee, did not work well with others, and that the employer would not rehire him. Based on that information, the county sheriff's commission removed the candidate from the hiring certification process. He sued, claiming that the county discriminated against him because of his race.

The district court ruled in favor of the county, finding no evidence that the decision to remove the candidate from the hiring certification process was related to his race. On appeal, the Seventh Circuit Court of Appeals agreed with the district court, finding no evidence that race played a role in the sheriff's merit commission's decision, rejecting the candidate's argument that the negative background check was a pretext to remove him from consideration. Instead, the Court found that the county had a legitimate, nondiscriminatory reason to remove him - the negative employment reference from his current employer.

Read More

Court Upholds Pension Board Decision to Award Non-Duty Disability Pension

Court Upholds Pension Board Decision to Award Non-Duty Disability Pension

  Tuesday, May 26, 2026    Julie Tappendorf

---

An Illinois Appellate Court upheld a pension board's award of a non-duty disability rather than a line-of-duty disability in Hull v. Village of Wheeling Police Pension Fund. 

A probationary police officer applied for a line-of-duty disability, claiming that a motor vehicle accident while on duty caused disabilities preventing him from returning to work. The pension board conducted a hearing, at which the officer presented evidence in favor of a line-of-duty pension and the village (as intervenor) presented evidence opposing the application, arguing that he was able to work and had, in fact, been employed in various jobs since the accident. The opinions of multiple medical professionals was also presented at the hearing, including evidence that the officer did suffer from depression that prevented him from continuing to work in his police officer position. At the conclusion of the hearing, the pension board voted to grant a non-duty disability pension to the former officer (who had since been terminated by the village), finding that he was disabled but not due to the motor vehicle accident.

The former officer appealed, and both the trial court and the Appellate Court upheld the pension board's decision that he was entitled to a non-duty disability pension, but not a line-of-duty pension. Both courts determined that the pension board relied on the opinions of multiple medical professionals that while his condition was disabling, it was not caused by the motor vehicle accident. 

Read More

Updates on Senate Bill 3336 (E-Bikes, etc)

Updates on Senate Bill 3336 (E-Bikes, etc)

  Thursday, May 21, 2026    Julie Tappendorf

---

We previously reported about Illinois Senate Bill 3336, which if passed by both houses of the Illinois General Assembly and signed by the Governor, would make comprehensive changes to the authority of local governments to regulate several devices and vehicles, including electric mobility devices (EMDs), motor driven cycles, low-speed electric bicycles, and low-speed gas bicycles. We wanted to share a couple of updates to the bill, including House Floor Amendments No. 2 and No. 3.

House Floor Amendment No. 2 was introduced on May 11, 2026, and subsequently recommended for adoption by the House Transportation: Vehicles and Safety Committee. This amendment would make several additional noteworthy changes to Senate Bill 3336, some of which are summarized below.

If passed, the amendment would authorize park districts, forest preserve districts, conservation districts, and transit districts, by ordinance or resolution, to regulate the use of EMDs, low-speed gas bicycles, and low-speed electric bicycles on bicycle paths in their respective jurisdictions. This proposed change is important, because Senate Bill 3336 otherwise expressly preempts local governments (including home rule units) from regulating EMDs, motor driven cycles, low-speed gas bicycles, and low-speed electric bicycles.

If passed, the amendment would also prohibit persons younger than 18 years old from operating low-speed electric bicycles and low-speed electric scooters manufactured to accommodate passengers, unless the passenger is a sibling, stepsibling, child, or stepchild of the operator. The amendment would also authorize operating low-speed gas bicycles on any highway, street, roadway, or bicycle lane authorized for use by regular bicycles.

The amendment also makes several important additions regarding mobility devices. Specifically, the amendment clarifies that nothing in the Illinois Vehicle Code prohibits the use of or reasonable accommodation for personal mobility devices when operated by persons with disabilities. The amendment also clarifies that the Vehicle Code’s rules for regular bicycles also apply to “adaptive electric bicycles,” which are defined to mean an electric bicycle with 2 or more wheels that is designed for and used by a person with a mobility disability.

House Floor Amendment No. 3 was introduced on May 21, 2026. If passed, it would add language exempting low-speed electric bicycles and low-speed gas bicycles from the driving while under the influence prohibitions unless the bicycle is capable of and operating in excess of 28 miles per hour. 

Stay tuned for more updates as this bill and any future amendments to it proceeds through the Illinois General Assembly.

Post Authored by Eugene Bolotnikov & Julie Tappendorf, Ancel Glink

    

Read More

Village Board Violated OMA by Not Including "General Subject Matter" of Action Item on Agenda

Village Board Violated OMA by Not Including "General Subject Matter" of Action Item on Agenda

  Tuesday, May 19, 2026    Julie Tappendorf

---

The Illinois Attorney General's Public Access Counselor (PAC) found a public body in violation of the Open Meetings Act (OMA) in its fifth binding opinion of 2026 for an inadequate agenda. PAC Op. 26-005.

A citizen filed a request for review with the PAC office claiming that a village board violated the OMA at a meeting where it voted on the termination of a village employee. Specifically, the citizen claimed that the agenda only listed "Personnel issues" under a "POLICE & LIQUOR" heading on the agenda, which he claimed was not sufficient to inform the public of the matter on which the village board was intending to take final action. The PAC agreed that the agenda description "Personnel issues" did not provide advance notice of the "general subject matter" of the action that was taken, and that the phrase "Personnel issues" was too broad as it could involve any number of other types of personnel actions, and not just termination of a village employee.

In its opinion, the PAC cited to section 2.02 of OMA that provides that "[a]ny agenda required under this Section shall set forth the general subject matter of any resolution or ordinance that will be the subject of final action at the meeting." As discussed in the past, the PAC appears to take a very expansive view of section 2.02 that would include actions taken by public bodies beyond votes on resolutions or ordinances (which section 2.02 seems to apply to). The PAC has applied section 2.02 to any type of action taken by a public body at a meeting, to include motions that do not involve an ordinance or resolution, even though the language of 2.02 expressly states that it applies to "the general subject matter of any resolution or ordinance..." (emphasis added). While unclear from the PAC opinion, it is possible that the village board may have acted on the termination via a resolution or ordinance, which would then clearly fall under section 2.02. In any event, it is advisable that an agenda of a meeting of a public body be sufficiently descriptive to inform the public of items that will be voted on at the meeting, whether those actions fall under 2.02 or otherwise. 

Read More

PAC Finds City Council in Violation of OMA for Closed Session Discussions

PAC Finds City Council in Violation of OMA for Closed Session Discussions

  Monday, May 18, 2026    Julie Tappendorf

---

The Illinois Attorney General's Public Access Counselor (PAC) issued its 4th binding opinion of 2026 finding a public body in violation of the Open Meetings Act (OMA) by discussing matters in closed session that were not outside the scope of a closed session exemption. PAC Op. 26-004.

A citizen filed an OMA complaint with the PAC claiming that a city council improperly held closed sessions to discuss the potential renovation of city hall and plans for a new city hall. In response to the complaint, the city argued that the city council discussed whether or not the city needed to look at purchasing land to build a new city hall, including discussing several properties that were listed for sale or that could be purchased. The city argued these discussions were proper under section 2(c)(5) of the OMA.

After listening to the verbatim tapes of the closed sessions, the PAC determined that part of the city council's discussions went beyond the scope of the OMA because they focused on the condition of the city hall property and financial matters, which the PAC determined were not proper under 2(c)(5) of the OMA. As a result, the PAC ordered the city to release that part of the verbatim recordings that exceeded the scope of the OMA but determined that the city council's discussions relating to purchase of property for a new city hall could be withheld as those discussions were within the scope of 2(c)(5) of the OMA.

Read More

Prosser Rule Applied to City Council's Appointment of Clerk

Prosser Rule Applied to City Council's Appointment of Clerk

  Thursday, May 14, 2026    Julie Tappendorf

---

It isn't often that the Illinois courts apply the "Prosser Rule" to the vote of a city council, but an Illinois Appellate Court did just that recently in Christian v. Buscher. 

In 2025, a city council held a special meeting to vote on the appointment of a person to fill a vacant city clerk position. The city council (made up of 10 elected aldermen and the mayor) voted five "yea," three "nay," and two "present" on the motion to approve an ordinance to appoint a sitting alderman to fill the clerk position. The mayor (who did not vote) announced that the measure passed. The alderman who was being appointed voted in favor of his appointment.

A citizen filed a lawsuit to challenge the vote on the appointment, arguing that the measure did not receive the necessary six votes to approve an ordinance. Specifically, the citizen argued that the two "present" votes should not have been counted towards the majority who did vote in favor of the measure. The citizen also argued that the favorable vote of the alderman who was being appointed should not have been counted. The circuit court dismissed the case and it was appealed to the Appellate Court.

The Appellate Court first analyzed the Illinois Supreme Court's Prosser v. Village of Fox Lake case where the Supreme Court held that an ordinance was validly approved even though a member of the board was present but did not vote, finding that the non-vote counted towards the majority of "yea" votes. The Court explained that if a measure requires an "affirmative" vote of the majority, then "voting to 'abstain,' or to 'pass,' or voting 'present' or of refusing to vote when present at a meeting" counts as a "nay" vote. However, if a measure requires a "concurrence" vote of the majority, a vote of pass, present, abstain, or a failure to vote counts as an acquiescence or concurrence with the majority, based on the "general rule" that those members present at a meeting "must vote against a proposal in order to defeat it." 

Because the city ordinances required a "concurrence of a majority" to pass an ordinance, the Court found that the ordinance being challenged was validly approved because the two "present" votes were properly counted with the "yea" votes based on the Prosser Rule. The Court also rejected the argument that the vote of the alderman being appointed should not have been counted, finding that even without his vote, the measure passed. As a result, the Appellate Court upheld the dismissal of the case challenging the appointment.

Read More

Removal of Tow Company from County Tow List Not a Due Process Violation

Removal of Tow Company from County Tow List Not a Due Process Violation

  Wednesday, May 13, 2026    Julie Tappendorf

---

In Tire Town Auto, LLC v. Wood County, the Seventh Circuit Court of Appeals found no due process violation when a county removed a tow company from the county's tow list. 

A Wisconsin county maintained a list of towing businesses that were available on a rotating basis to recover vehicles on public roads. After receiving complaints about one of the tow companies, the county removed it from the list and the company sued, claiming the county violated its procedural due process rights in removing it from from the tow list. The county asked the court to dismiss the lawsuit, arguing there is no protected property interest in being listed on the county's tow list. The district court agreed and dismissed the case, and the company appealed.

The Seventh Circuit upheld the district court's ruling, finding that the tow company did not allege or identify any written or other source that would support a property interest, including a statute, regulation, or ordinance that would guarantee a business a spot on the county's tow list. As a result, the case was properly dismissed.

Read More

Quorum Forum Podcast Ep. 105: Anatomy of a Redevelopment Agreement (Part 2)

Quorum Forum Podcast Ep. 105: Anatomy of a Redevelopment Agreement (Part 2)

  Friday, May 08, 2026    Julie Tappendorf

---

Ancel Glink's Quorum Forum Podcast has released a new episode, Episode 105: Anatomy of a Redevelopment Agreement (Part 2). 

In this episode, we return to the Southland Development Authority’s “TIF Talk” training series for a deep dive into the financial and practical implementation of economic development deals. Hosted by the Village of Hazel Crest, this session features Ancel Glink’s David Silverman, Michio Murakishi (Meech Group), and Terri Cox (Matanky Realty Group).

Building on the structural overview provided in Quorum Forum 97:  Anatomy of a Redevelopment Agreement, the panel explores how municipalities can use RDAs to bridge financial gaps and ensure projects are feasible for developers while protecting the public interest.

Highlights:

• The Math of Incentives: Understanding Internal Rate of Return (IRR), yield on cost, and how consultants use gap analysis to size incentives.
• The “But For” Test:  A look at the legal and financial necessity of incentives, and the idea that a project would not happen “but for” the public assistance.
• Net Public Benefit:  How to measure the “dividend” of a public investment through tax base growth, job creation, and revitalized storefronts.
• Case Studies from the Trenches:  Terri Cox shares lessons from the Bishop Classic project in Chicago and a $5 million car wash development on Dixie Highway in Harvey.
• Performance-Based Protections:  The importance of clawback provisions, reimbursement schedules, and why the public sector should generally avoid being a landlord.

Read More