SPRINGFIELD, Ill. (WCIA) — A Springfield attorney is being fined and could face additional penalties after admitting to using artificial intelligence in briefs where he cited eight “nonexistent” cases — a situation that may be the first of its kind in the Illinois Appellate Court.

On Nov. 4, 2024, the circuit court of Sangamon County appointed Springfield attorney William T. Panichi to represent someone in an accelerated appeal from the termination of the respondent’s parental rights filed under an Illinois Supreme Court rule.

An opinion filed on July 21, 2025 by Carla Bender in the Fourth District Appellate Court states that following an in-depth review of the briefs, the court recognized that Panichi cited eight “apparently nonexistent” cases in the respondent’s opening and reply briefs. In one instance, he provided a direct quote from one of these cases.

Being concerned that the respondent’s briefs contained citations to apparently nonexistent cases, this court ordered Panichi to file copies of the following cases:

• In re M.F., 2022 IL App (2d) 210614
• In re A.G., 2022 IL App (1st) 220119
• In re R.C., 195 Ill. App. 3d 827 (1st Dist. 1990)
• In re R.D.S., 2021 IL App (2d) 200092
• In re M.H., Jr., 196 Ill. App. 3d 976 (1st Dist. 1990)
• In re Brandon E., 382 Ill. App. 3d 389 (2d Dist. 2008)
• In re K.L.P., 381 Ill. App. 3d 817 (4th Dist. 2008)
• In re Ca. B., 386 Ill. App. 3d 507 (2d Dist. 2008)

Panichi was then further ordered to appear before this court personally and to show why he should not be sanctioned.

As a result, on June 16, 2025, Panichi filed a two-page response to this court’s rule. In part of his response, he stated that two of the eight cases accused of being nonexistent were “valid, published Illinois Appellate Court decisions” and were “properly cited.”

He also said that another one of the cases is a “valid published decision but was incorrectly cited.” Later in his response, Panichi admitted that the five remaining citations in the Appellant’s Brief were determined to be nonexistent or invalid.

On June 18, 2025, he appeared before the court and acknowledged he was familiar with principles in the Illinois Supreme Court and rules of the state’s Professional Conduct. He also said that he was compensated for his work at the rate of $150 per hour for a total of $6,925.

Panichi later said that the payment he received for this case “was more than [he] usually charges[s]” and that this case “was out of the ordinary in terms of time spent” because his office “did some exceptional work trying to get some other information before the court” by filing “a brief trying to open up the proofs,” but he did not remember the exact matter.

Addressing Panichi’s response, the court pointed out to him that despite his claims that two of the cases were valid and properly cited, he had actually cited in his brief two completely different citations.

He said that he was not currently familiar with the content of the cases but claimed he had been so at one time. He also admitted that he did not read either of these decisions prior to filing his response to the court’s rule to show cause.

Panichi said he misread the court’s rule to show cause as citing “Brandon A.,” when it cited “Brandon E.” He also acknowledged that he did not list a citation for “Brandon E.” in his response and never looked up whether “Brandon E.” existed.

The court said during the hearing that a case Panichi claimed to have intended to cite did not contain the quotation for which he cited in his reply brief. He then admitted he did not know where he obtained the quote and did not believe it was accurate.

As a result, the court stated that Panichi may have mislead the court.

Later on, Panichi said his incorrect citations in the briefs he attached to his response to the rule to show cause “might be an example of poor lawyering, poor arguing, stretching principles, I don’t have an answer for that.”

On the other hand, he then claimed that “to the best of [his] knowledge, [these cases] were cited for the appropriate principles.” However, he did admit that he had only read one of the three cases he attached to his response and could not remember which one.

This court then turned to Panichi’s response and asked about how the five nonexistent citations appeared in his brief. At first, he clarified that he did not claim to have an “excuse,” just an “explanation.”

Panichi then admitted that in preparing the briefs and conducting research in this case, he used artificial intelligence to write a draft of the brief, then “looked it over and [he] did not read the cases that were in support of the brief.”

He further explained that at the time he filed the briefs, he was both “extremely busy” and “not thorough enough.” Panichi stated that his use of AI was prompted by a “perfect storm” of “temptation of AI out there at a time when [he] was busy and trying to meet deadlines.”

Panichi also claimed to have since learned about AI “hallucinations,” in which the AI “dreams things up when it doesn’t have an answer.” He acknowledged that he should have read the cases that the AI presented to him and admitted he was “between research software” when he prepared the briefs.

He told the court he did not intend to use AI anymore going forward.

Panichi admitted that “the whole thing stems from the fact that [he] barely did any personal work [him]self on this appeal.” He further said he was careless and reckless in his actions and said he was wrong for what he did.

He also acknowledged that while he relied on the legal assistant in his Springfield office a great deal, he, as the attorney, was ultimately responsible in this matter.

As a result of this situation, Panichi has been ordered the following sanctions:

• He must disgorge the payment of $6,925.62 he received for his work on this appeal to the Sangamon County treasurer within 30 days of the filing of this opinion and must submit, within five days after payment, a receipt to this court reflecting the payment
• He must pay $1,000 as monetary sanctions to the clerk of the Fourth District Appellate Court within 30 days of the filling of this opinion
• The clerk of the Fourth District Appellate Court shall send a copy of this opinion to the Illinois Attorney Registration and Disciplinary Commission

The opinion also stated that this appears to be the first issued opinion in the Illinois Appellate Court to address the citation of fictitious cases generated by AI, and the additional penalty of $1,000 was issued to help deter other attorneys from following in Panichi’s footsteps.

Panichi shared the following statement with WCIA as a result of this opinion:

“I want to apologize to the Appellate Court for the extra trouble I put them through. I am responsible for this without any excuse, and I am working on closing out my practice appropriately and surrendering my license.”

Attorney William T. Panichi

The opinion also stated that nothing within it is intended to “categorically forbid attorneys from using AI tools.” The Illinois Supreme Court AI policy even explicitly permits the use of AI. However, it urges attorneys to use AI tools “wisely.”

“We reiterate the supreme court’s reminder that ‘[a]ll users must thoroughly review AI-generated content before submitting it in any court proceeding to ensure accuracy and compliance with legal and ethical obligations.”’AI Policy, supra,” part of the opinion states.