The Seventh Circuit Court of Appeals issued an opinion Tuesday in *Solomon A. Jones v. Kankakee County Sheriff's Department* that highlights emerging concerns about artificial intelligence use by self-represented litigants in federal court.
Solomon Jones, representing himself in a civil rights lawsuit, filed suit in November 2023 under 42 U.S.C. § 1983 against several municipal and county entities in Kankakee, Illinois. Jones alleged the defendants violated his constitutional rights during a series of 2023 incidents involving ticketing and arrests for trespassing and disorderly conduct.
The Seventh Circuit, in an opinion authored by Circuit Judge Scudder, remanded the case to the U.S. District Court for the Central District of Illinois. The court noted that recent developments in related state court litigation required the district court to reconsider aspects of Jones's federal claims.
"The issues presented by his appeal are straightforward and lead us without difficulty to return the case to the district court," the court wrote, referring to the need to account for the state court developments.
However, the opinion took an unusual turn when addressing concerns about Jones's reply brief on appeal. Despite Jones's assertions that he did not use artificial intelligence to prepare his legal documents, the court expressed skepticism about his claims.
"What is less straightforward is what to make of legal representations in the reply brief Jones filed on appeal," Circuit Judge Scudder wrote. "Though he tells us he did not use artificial intelligence to prepare the brief, we are skeptical, as his brief attributed quotations to two cases that do not appear in those cases."
The court's skepticism centered on misattributed quotations in Jones's brief. Legal briefs typically include citations to court cases with accompanying quotations from those decisions to support legal arguments. In Jones's case, the Seventh Circuit found that quotations he attributed to specific cases were not actually found in those decisions.
Such errors have become increasingly associated with artificial intelligence tools that can generate legal-sounding text and citations but may fabricate case quotations or citations entirely. Legal professionals have documented numerous instances where AI tools have created fictional cases or misattributed real quotations to incorrect sources.
Despite the court's suspicions about potential AI use, the Seventh Circuit chose not to impose sanctions on Jones. Instead, the court indicated it would offer observations about considerations unique to AI use by pro se litigants.
The decision reflects growing judicial awareness of artificial intelligence's role in legal practice, particularly among self-represented parties who may lack the resources to hire attorneys. Pro se litigants often face significant challenges navigating complex legal procedures and may turn to AI tools for assistance in drafting court documents.
Jones's original lawsuit was described by the court as "sprawling," suggesting the complexity typical of pro se civil rights cases. The plaintiff alleged constitutional violations arising from his interactions with local law enforcement and municipal authorities in Kankakee County.
The case originated in the U.S. District Court for the Central District of Illinois under Judge Colin S. Bruce. After Jones filed his initial lawsuit, the court noted that he "peppered the district court with motions," indicating active litigation management typical of pro se cases.
The Seventh Circuit's decision to remand rather than resolve the appeal on the merits demonstrates the impact of parallel state court proceedings on federal civil rights litigation. Courts must often coordinate between federal and state forums when related claims arise from the same underlying facts.
The timing of the decision, submitted December 22, 2025, and decided January 21, 2026, shows the court's efficient handling of what it characterized as straightforward issues requiring remand.
The court panel included Chief Judge Brennan and Circuit Judges Scudder and St. Eve, who agreed to decide the case without oral argument. The judges determined that the briefs and record adequately presented the legal arguments without need for additional oral proceedings.
This case joins a growing body of judicial opinions addressing artificial intelligence in legal practice. Courts nationwide have begun implementing rules requiring disclosure of AI use in legal documents, while others have sanctioned attorneys for submitting AI-generated content containing fictional citations.
For pro se litigants like Jones, the intersection of AI technology and self-representation presents unique challenges. While AI tools may offer assistance to those who cannot afford legal counsel, the technology's limitations in legal research and writing pose risks for unrepresented parties.
The Seventh Circuit's approach of expressing skepticism without imposing sanctions suggests judicial recognition of these complexities. Rather than punishing potential AI use, the court chose to use the case as an opportunity to address broader considerations about artificial intelligence in pro se litigation.
The remand means Jones's case will return to the district court for further proceedings that account for developments in related state litigation. How the district court handles any AI-related concerns may provide additional guidance for self-represented litigants considering artificial intelligence assistance in their legal cases.