Appellate Court Dismisses A.I. Generated Appeal Brief: Officer Failed to Follow Medical Advice and Court Rules
In Pletcher v. Libertyville Police Pension Fund, the Illinois Appellate Court dismissed the Plaintiff’s appeal seeking to reverse the Pension Board’s denial of disability benefits. This case involved Bryan Pletcher, who filed an appeal against the Libertyville Police Pension Board. The appeal was dismissed due to violations of Illinois Supreme Court Rules by the officer, who was representing himself pro se.
Pletcher, a police officer hired by the Village of Libertyville in 2003, initially applied for a non-duty disability pension in 2020 due to congestive heart failure but later withdrew his application and returned to duty. In 2022, after receiving a reprimand and being placed on a performance improvement plan, he filed a second application for disability, citing additional health issues including myocarditis, heart failure, and cardiomyopathy.
The Libertyville Pension Board held hearings in 2023, during which it was revealed that Pletcher had not consistently followed medical advice, leading to the exacerbation of his conditions. Three doctors examined him and concluded that his condition could have been controlled with proper medication compliance. The Board denied his application, stating that his condition could be remedied without significant danger to life, health or extraordinary suffering if he adhered to medical advice. Specifically, all the medical evidence in the record supported a conclusion that the prescribed medications offered a reasonable prospect for relief. The Applicant’s refusal to consistently take his medications and to stop taking his medications against the advice of all his doctors was not reasonable or within the bounds of reason. All the medical evidence supported a conclusion that if the Applicant took his medications he (1) would not have developed hypertensive nonischemic cardiomyopathy and (2) he would recover from his hypertensive nonischemic cardiomyopathy such that he could perform full unrestricted police duties. Every doctor testified that but for the Applicant’s refusal to undergo reasonable medical treatment, the Applicant would not have developed hypertensive nonischemic cardiomyopathy.
Pletcher filed an appeal, however his appellate brief contained numerous fictitious citations and quotes, many of which were generated by artificial intelligence. The Board filed a motion for sanctions, citing violations of Illinois Supreme Court Rules, including fictitious citations and non-existent authorities. The Court noted that Pletcher, despite being pro se, was expected to comply with Court rules. His reliance on A.I.-generated content without ensuring its accuracy was deemed a violation of Court rules. The Court granted the Board’s motion to strike Pletcher’s brief and dismissed the Appeal, emphasizing that pro se litigants are presumed to have full knowledge of Court rules and must comply with them.