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Appeals court fines lawyer in Starbucks bias case $15K for AI-generated fake citations

United States·ABA Journal — Litigation·⏱️ 2 min readWire Summary

By Shirley Henderson August 4, 2026, 11:56 am CDT An Illinois appeals court has upheld the Illinois Human Rights Commission’s dismissal of a race discrimination charge brought by a Starbucks employee against the Starbucks Coffee Co. (Photo from Shutterstock ) An Illinois appeals court has upheld the Illinois Human Rights Commission’s dismissal of a race discrimination charge brought by a Starbucks employee against the Starbucks Coffee Co., and it has sanctioned her attorney $15,000 for submitting court documents containing artificial intelligence-fabricated legal citations. Lawyer Mason Cole of Cole Sadkin submitted briefs on behalf of Starbucks employee Kimberly Scott with false citations, quotes and even a fictitious case, the Illinois Appellate Court for the First District found. It also determined that the mistakes were generated by AI hallucinations created by the chatbot that Cole used to draft his briefs. In a written response to the appeals court, he admitted to using a “premier corporate subscription of ChatGPT” to explain complex legal issues. He also said he cross-referenced the citations with LexisNexis but didn’t catch the errors, according to coverage by AlabNews . The appeals court, which upheld a decision by the Illinois Human Rights Commission to dismiss the race discrimination charge by Scott, imposed a flat $1,500 penalty per false citation on Cole. It also cited Rule 375 by the Illinois Supreme Court and the Illinois Rules of Professional Conduct regarding the attorney’s conduct. The clerk of the Illinois Appellate Court for the First District was directed to forward the court’s opinion to the Illinois Attorney Registration & Disciplinary Commission, which investigates and disciplines lawyers. Appeals court imposes higher sanction on attorney to deter unacceptable misuse of AI

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