An AI assistant might help you explain why you believe a court got your case wrong. It might organize your arguments and make your writing clearer. But an appeal also depends on what happened before that draft: what evidence was presented, what proceedings were recorded, and what materials properly became part of the appellate record.

That creates a risk for someone representing themselves, often called appearing pro se. A document can become easier to read while an essential part of the case remains missing. Knowing what to ask an AI assistant requires some understanding of what the court will need.

Livingston County v. Morris, 2026 IL App (4th) 260216-U, illustrates the consequences. The Illinois Appellate Court dismissed a self-represented litigant's appeal because of substantial briefing deficiencies. It then explained that even if it excused those deficiencies, the inadequate record would require it to affirm the trial court's order. Improving the brief alone would have left a separate obstacle. (Morris, ¶¶ 19–23)

The order does not say Morris used AI. Its relevance to AI-assisted self-representation is the distinction it exposes between generating legal language and preparing a case for judicial review.

What happened in Morris

The dispute concerned enforcement of a local zoning ordinance prohibiting junkyards. The trial court authorized Livingston County to enter Morris's property and have third parties remove personal property as necessary to bring it into compliance. Morris appealed, raising issues including due process, excessive fines, unreasonable search and seizure, judicial bias, and service of process. (Morris, ¶¶ 2, 6, 9)

The appellate court identified deficiencies that prevented it from meaningfully addressing those issues. Morris's factual presentation contained brackets and blank lines where record citations apparently were intended, but no actual citations. It also omitted facts concerning the merits. Her arguments stated broad legal principles without explaining how they applied to the evidence in her case. (Morris, ¶¶ 14–19)

The court acknowledged the severity of dismissal and struck the brief. It also emphasized that appearing without a lawyer did not excuse compliance with Illinois's appellate briefing requirements. (Morris, ¶¶ 11–12, 24–27)

Under Illinois Supreme Court Rule 341, an appellant's brief must present the necessary facts accurately and fairly, with references to the appellate record. Its argument must explain the appellant's position and reasons, citing the authorities and record pages relied upon. These requirements give the reviewing court a way to evaluate the asserted error. (Rule 341(h)(6)–(7))

Morris's excessive-fines argument shows why that connection matters. According to the court, she asserted that the enforcement measures were grossly disproportionate and unconstitutional, but did not supply meaningful factual analysis of the fines, enforcement measures, or severity of the zoning violation. Stating the constitutional objection did not explain why it warranted relief in this case. (Morris, ¶¶ 17–18)

An AI-assisted draft needs that same connection. Finding a legal principle is only part of the work. Someone must determine whether it applies, identify the evidence relevant to it, and verify that the cited record supports the argument. More confident wording does not complete those tasks.

A stronger brief would still have left an incomplete record

There were exhibits, including photographs, in the appellate record. But there were no transcripts of the hearings. Morris had filed a bystander's report, a narrative account intended to document proceedings when a verbatim transcript is unavailable. The appellate court could not find certification of that report in the record or docket entries, and the record did not show service on the county. The report also omitted facts concerning the testimony and evidence on the merits. (Morris, ¶¶ 6–7, 22)

Illinois Rule 323 provides alternatives to a verbatim transcript, including a bystander's report and an agreed statement of facts. Those alternatives have procedural requirements. For a bystander's report, the rule addresses service, settlement, and court certification; absent stipulation, only the certified report may be included in the appellate record. A written account of a hearing does not automatically satisfy that process. (Rule 323(c)–(d))

Applying the principle that the appellant must supply a record sufficient to support the claimed error, the court said it would affirm if it reached that issue despite the briefing deficiencies. The actual disposition remained dismissal. (Morris, ¶¶ 20–27)

An AI assistant might help organize recollections or identify questions about a missing transcript. Its output does not itself establish what occurred, obtain the required approval, or demonstrate that procedural steps were completed. The person handling the appeal must still address those matters.

Using AI while recognizing the remaining work

The practical risk is treating progress on a document as proof that the case is ready. Even an accurate explanation of the law cannot establish that the necessary evidence is in the appellate record or that the filing meets every applicable requirement.

For someone using AI, useful questions extend beyond how to strengthen an argument:

  • Which factual statements can I trace to specific materials in the record?
  • What does the evidence show that might weaken my position?
  • What information or procedural step remains unverified?
  • Which questions need a lawyer's judgment before I act?

An assistant's answers need verification too. A checklist generated from incomplete information can leave out the very issue that matters.

Some people represent themselves because legal help is difficult to obtain or afford. That makes practical support especially valuable. AI can be used to organize documents, prepare a chronology, and develop questions for a consultation. If full representation is out of reach, asking about legal aid or assistance with a defined part of the case may help. The Illinois Courts' self-help resources include civil-appeal information, legal-aid links, and referrals to lawyer services.

The lesson from Morris is that responsibility extends beyond the words in the brief. AI assistance can be useful while those responsibilities remain substantial. The litigant still bears the consequences of what was omitted, unsupported, or procedurally incomplete.

Source note: Morris was filed October 16, 2026, as a Rule 23 order. It is nonprecedential except in the limited circumstances allowed by that rule. The AI discussion is an educational application of the order, not a finding about Morris's conduct or a test of any AI system.