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Scott v. Illinois Human Rights Comm'n · редакция 1 → 2 · зафиксировано 2026-09-17 03:56 · +3 −3 lines

2026 IL App (1st) 251462
¶ 51 Courts in other jurisdictions have imposed stricter sanctions. For example, in a Sixth
Circuit case,the appellant’s briefs included dozens of fake citations and misrepresentations of fact.
Circuit case, the appellant’s briefs included dozens of fake citations and misrepresentations of fact.
Whiting v. City of Athens, 170 F.4th 455, 458 (6th Cir. 2026). The court ordered the appellant’s attorneys to file a response explaining these misrepresentations, and they refused. Id. at 459. The court found that the appeal was frivolous because the appellant’s arguments were based on fake cases and fabricated holdings. Id. at 461. The court sanctioned the attorneys by requiring them to pay the appellees’ attorney fees and double their costs, as well $15,000 each in fines. Id. at 466-
District, within 30 days of this opinion. See Baby Boy, 2025 IL App (4th) 241427, ¶ 130. We impose this sanction pursuant to Rule 375(a) and 375(b), both of which authorize monetary fines.
Ill. S. Ct. R. 375(a), (b) (eff. Feb. 1, 1994).Attorney Cole’s briefs contain a total of 10 false citations: 4 false statutory quotations, 1 nonexistent case, and 5 cases that exist but do not contain the cited principle or quoted language. This sanction reflects a $1,500 fine for each false citation and quotation.
Ill. S. Ct. R. 375(a), (b) (eff. Feb. 1, 1994). Attorney Cole’s briefs contain a total of 10 false citations: 4 false statutory quotations, 1 nonexistent case, and 5 cases that exist but do not contain the cited principle or quoted language. This sanction reflects a $1,500 fine for each false citation and quotation.
¶ 57 We recognize that this rate is somewhat higher than what courts have imposed in the past.
Although the Act places this requirement in a list of items the Department must notify the complainant of, it unambiguously requires the complainant to “submit a copy of the EEOC’s determination within 30 days after service of the determination by the EEOC on the complainant.”
775 ILCS 5/7A-102(A-1)(1)(iv) (West 2022). This requirement is jurisdictional because “[a]n administrative agency’s powers are limited to those granted by the legislature and any action taken by an agency must beauthorized specifically by statute.” Ferris, Thompson & Zweig, Ltd.
775 ILCS 5/7A-102(A-1)(1)(iv) (West 2022). This requirement is jurisdictional because “[a]n administrative agency’s powers are limited to those granted by the legislature and any action taken by an agency must be authorized specifically by statute.” Ferris, Thompson & Zweig, Ltd.
v. Esposito, 2015 IL 117443, ¶ 16. Here, the statute provides that, when a complainant files charges with both the EEOC and the Department, the Department cannot act while the EEOC is investigating. 775 ILCS 5/7A-102(A-1)(1) (West 2022). The Department can act only when the
Kwame Raoul, Attorney General, of Chicago (Jane Elinor Notz, Solicitor General, and Emily A. Vernon, Assistant Attorney General, of counsel), for respondents.