BEFORE YOU FILE · EXERCISE 01

Every citation is real.
Would you file it?

A draft can cite real cases and still leave essential work undone. Read the brief, inspect the packet, and decide what you would do next.

About 5 minutesNo account needed

A judgment exercise from Jonathan Nessler.

Citation existence checked 3 real authorities

This is a supplied premise of the exercise, not a live verification result. What else would you check?

THE SOURCE PACKETRead the fictional case file

Use these supplied facts to review the draft below.

The purchase papers: Mara Ellis signed a purchase contract as buyer or assignee. The deed names Harbor Lane, LLC as owner. Ellis is its sole member. Seller’s representative Owen Hart signed the contract only on behalf of the seller.
The pleading and dismissal: Ellis alleges water damage and seeks repair costs from Hart individually for breach of contract. The dismissal order says the complaint identifies no contractual obligation owed by Hart personally. The supplied materials identify no particular contract term he allegedly breached.
The hearing materials: A later written order denies Ellis’s motion to reconsider and for leave to amend. It records that the court heard argument and was advised in the premises. No transcript, bystander’s report, or agreed statement of facts has been supplied.
The named plaintiff: Ellis, who is not a lawyer, initially filed for Harbor Lane, LLC. She later substituted herself as plaintiff and continued without counsel. The supplied materials do not explain whether the repair claim belongs to Ellis or the LLC.

DRAFT FOR REVIEWEXERCISE 01

Argument

A fictional excerpt prepared for this exercise.

I. The dismissal should be reversed.

An appellate argument must explain the claimed error and support it with relevant authority. Wells Fargo, ¶ 43. Ellis’s complaint describes the property’s water damage and seeks the cost of repairs from Hart. These allegations establish the basis for relief and demonstrate why dismissal was improper. The court should reverse and permit Ellis to proceed with her contract claim.

Wells Fargo Bank, N.A. v. Sanders, 2015 IL App (1st) 141272, ¶ 43

II. The court should have allowed amendment.

Denial of postjudgment leave to amend is reviewed for abuse of discretion. Maniscalco, ¶ 29. At the hearing, the judge rejected Ellis’s account of the damage and accepted the seller’s version instead. That choice was unreasonable. The written order confirms that argument occurred, supporting Ellis’s challenge to the ruling. The court should reverse and allow an amended complaint.

Maniscalco v. Porte Brown, LLC, 2018 IL App (1st) 180716, ¶¶ 29–30

III. The amended caption resolves representation.

A nonlawyer’s filing for a corporation does not require automatic dismissal; the court must consider the circumstances. Downtown Disposal, ¶ 31. Ellis subsequently amended the complaint to name herself and no longer seeks relief in the company’s name. That amendment resolves the representation issue and permits Ellis, as the LLC’s sole member, to pursue the property’s repair costs in her individual capacity.

Downtown Disposal Services, Inc. v. City of Chicago, 2012 IL 112040, ¶ 31

END OF EXCERPT

THE CASE BEHIND THE EXERCISE

What happened
in Rhyu v. Frost?

2026 IL App (1st) 252257
Decision filed September 29, 2026

Read the court’s decision (PDF)

In Rhyu v. Frost, 2026 IL App (1st) 252257, the trial court identified nonexistent citations, which it described as AI hallucinations, as an additional reason for dismissing an already deficient complaint with prejudice. The appellate court affirmed, addressing undeveloped arguments and an incomplete record. It also identified the LLC representation problem as an alternative ground for affirmance.

The people, packet, and draft above were written for this exercise. They are not excerpts from the parties’ filings. The exercise draws on issues discussed in the decision; it does not suggest that fixing one defect would have changed the result.

Read the full walkthrough

REVIEW 01

The draft never answers the dismissal order’s actual reason.

The packet says Hart signed only for the seller. The draft identifies neither a personal contractual obligation nor a breached term, then declares the claim sufficient. Its authority concerns appellate briefing, not Hart’s liability. In Rhyu, the appellate court rejected undeveloped arguments that did not connect the cited law to an identifiable error in the trial court’s ruling.

Next step: Identify the challenged ruling, the relevant legal rule, and the specific allegations or record pages supporting each step. Determine whether a supported argument is available.

Rhyu v. Frost, ¶¶ 22–26 · pages 7–9

REVIEW 02

The draft asserts hearing details the packet does not supply.

The packet supplies an order confirming that argument occurred, but no account of that argument. It cannot support the draft’s claim that the judge chose the seller’s version. In Rhyu, the missing hearing record prevented review of the claimed error on reconsideration; the appellate court presumed the ruling had a sufficient legal and factual basis.

Next step: Check what the appellate record actually contains. Investigate whether a transcript or permitted substitute can be obtained, and remove assertions the available record cannot support.

Rhyu v. Frost, ¶¶ 27–29 · pages 9–10

REVIEW 03

The draft treats the individual and her LLC as interchangeable.

The deed names the LLC, and the packet leaves ownership of the repair claim unresolved. Changing the plaintiff’s name does not establish Ellis’s right to recover. In Rhyu, the appellate court found that the LLC still appeared to be the true party in interest and treated the nonlawyer’s substantial participation as an alternative ground for affirmance. It also recognized that dismissal is not automatic.

Next step: Trace the agreement, ownership, alleged injury, and any assignment. Determine whose claim is being pursued and address the LLC’s need for counsel before drafting a conclusion.

Rhyu v. Frost, ¶¶ 30–32 · pages 10–11

PUT IT INTO PRACTICE

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