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Kettering Adventist Healthcare v. Sandra Collier, et al.
S.D. Ohio · Feb 25, 2026
Direct answer
What happened in this matter?
The court found counsel in contempt and violated Rule 11(b) for submitting over a dozen fabricated and misrepresented citations generated by AI. The court struck the motion to dismiss and imposed a $7,500 total monetary sanction ($5,000 against Scott; $2,500 against Hewitt), while referring both attorneys to state disciplinary authorities.
- Why the court cared
- Misrepresented: Case Law | Counsel cited United States v. Pendergraft, 297 F.3d 1198 (11th Cir. 2002) as supporting civil-extortion elements; the Court noted Pendergraft addresses criminal extortion under the Hobbs Act, not civil extortion under Ohio law (misapplied authority). || Fabricated: Case Law | Counsel cited 'State v. Carter, 72 Ohio App. 3d 553 (2d Dist. 1991)' as authority for an element of civil extortion; the court's review found no such opinion supporting that proposition (case appears non-existent/mislinked). || Fabricated: Case Law | Counsel relied on 'In re Protech, 51 F.4th 714 (6th Cir. 2022)' in briefing; the Court's independent review found no Sixth Circuit opinion matching that citation (phantom citation). || Fabricated: Case Law | Counsel cited 'Dart Indus. Co. v. Hurd, 66 Ohio St. 2d 280 (1981)' for protection of settlement demand letters; the Court determined that citation was fabricated/misleading and not applicable as asserted. || Misrepresented: Case Law | Counsel cited Kenty v. Transamerica Premium Ins. Co., 72 Ohio St.3d 415 (1995) as addressing extortion-related settlement privilege; the Court found Kenty does not support that proposition (misstated holding). || Misrepresented: Case Law | Counsel cited Office Depot, Inc. v. Impact Office Prods., LLC, 821 F. Supp. 2d 912 (N.D. Ohio 2011) for a particular pleading/particularity rule for DTSA/OUTSA; Court found the cited passages do not state the proposition relied upon (mischaracterized authority). || Misrepresented: Case Law | Counsel cited 'State ex rel. Ellis v. Cleveland Mun. Sch. Dist., 2015-Ohio-760' as supporting that settlement demand letters are non-actionable; Court found the cited authority was actually a different federal case (309 F. Supp. 2d 1019) and irrelevant to proposition. || False Quotes: Case Law | Counsel quoted or paraphrased United States v. Jackson, 180 F.3d 55 (2d Cir. 1999) as saying that informing authorities of misconduct cannot be an unlawful threat; the Court found no such language in Jackson and that the opinion does not stand for the asserted proposition. || Fabricated: Case Law | Counsel relied on 'State v. Milam, 2022-Ohio-3965 (10th Dist.)' for an extortion element; the Court found no such case addressing extortion (citation does not support proposition / appears nonexistent).
- Why it matters now
- Ten bad citations in one brief drew $7,500 plus contempt — cap any brief's citations until a second attorney signs off.
Why this matter is tracked
Counsel Mary T. Scott and H. Lean Hewitt submitted multiple filings containing over a dozen fabricated and misrepresented case law citations, including 'phantom' cases and mischaracterized holdings. Despite being notified by opposing counsel of these inaccuracies, counsel failed to verify the citations and continued to rely on them in subsequent filings and mediation statements. The court found that counsel violated Federal Rule of Civil Procedure 11(b) and Ohio Rule of Professional Conduct 3.3(a)(1). The court held both attorneys in contempt, struck the offending motion to dismiss, and imposed monetary sanctions totaling $7,500. The court further referred the attorneys to the Ohio Office of Disciplinary Counsel and recused itself from the proceedings.
Operational lesson
Ten bad citations in one brief drew $7,500 plus contempt — cap any brief's citations until a second attorney signs off.
Record details
OhioSingle-state evidence scope
CourtS.D. Ohio
Jurisdictionfederal
Circuit6th Circuit
DateFeb 25, 2026
GE
AI toolGenerative artificial intelligence (unspecified)
Party typeLawyer
OutcomeContempt finding, motion to dismiss stricken without prejudice, and $7,500 in total monetary sanctions.
Known amount$7,500
Professional sanctionReferral to the Supreme Court of Ohio's Office of Disciplinary Counsel for potential further professional discipline.
Attribution boundary
What the record establishes about AI use
admitted
Counsel admitted to using generative AI for research.
Procedural posture
The court issued a Show Cause Order following a January 2, 2026, decision identifying fraudulent citations. Following responses from counsel, the court issued a final order on February 25, 2026, imposing sanctions, finding contempt, and recusing itself.
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
9 citation, quotation, or authority issues are recorded in the source dataset.
- Misrepresented: Case Law | Counsel cited United States v. Pendergraft, 297 F.3d 1198 (11th Cir. 2002) as supporting civil-extortion elements; the Court noted Pendergraft addresses criminal extortion under the Hobbs Act, not civil extortion under Ohio law (misapplied authority).
- Fabricated: Case Law | Counsel cited 'State v. Carter, 72 Ohio App. 3d 553 (2d Dist. 1991)' as authority for an element of civil extortion; the court's review found no such opinion supporting that proposition (case appears non-existent/mislinked).
- Fabricated: Case Law | Counsel relied on 'In re Protech, 51 F.4th 714 (6th Cir. 2022)' in briefing; the Court's independent review found no Sixth Circuit opinion matching that citation (phantom citation).
- Fabricated: Case Law | Counsel cited 'Dart Indus. Co. v. Hurd, 66 Ohio St. 2d 280 (1981)' for protection of settlement demand letters; the Court determined that citation was fabricated/misleading and not applicable as asserted.
- Misrepresented: Case Law | Counsel cited Kenty v. Transamerica Premium Ins. Co., 72 Ohio St.3d 415 (1995) as addressing extortion-related settlement privilege; the Court found Kenty does not support that proposition (misstated holding).
- Misrepresented: Case Law | Counsel cited Office Depot, Inc. v. Impact Office Prods., LLC, 821 F. Supp. 2d 912 (N.D. Ohio 2011) for a particular pleading/particularity rule for DTSA/OUTSA; Court found the cited passages do not state the proposition relied upon (mischaracterized authority).
- Misrepresented: Case Law | Counsel cited 'State ex rel. Ellis v. Cleveland Mun. Sch. Dist., 2015-Ohio-760' as supporting that settlement demand letters are non-actionable; Court found the cited authority was actually a different federal case (309 F. Supp. 2d 1019) and irrelevant to proposition.
- False Quotes: Case Law | Counsel quoted or paraphrased United States v. Jackson, 180 F.3d 55 (2d Cir. 1999) as saying that informing authorities of misconduct cannot be an unlawful threat; the Court found no such language in Jackson and that the opinion does not stand for the asserted proposition.
Show 1 additional discrepancies
- Fabricated: Case Law | Counsel relied on 'State v. Milam, 2022-Ohio-3965 (10th Dist.)' for an extortion element; the Court found no such case addressing extortion (citation does not support proposition / appears nonexistent).
Questions this record answers
- What happened in Kettering Adventist Healthcare v. Sandra Collier, et al.?
- The court found counsel in contempt and violated Rule 11(b) for submitting over a dozen fabricated and misrepresented citations generated by AI. The court struck the motion to dismiss and imposed a $7,500 total monetary sanction ($5,000 against Scott; $2,500 against Hewitt), while referring both attorneys to state disciplinary authorities.
- Why does Kettering Adventist Healthcare v. Sandra Collier, et al. matter for legal AI risk?
- Ten bad citations in one brief drew $7,500 plus contempt — cap any brief's citations until a second attorney signs off.
- What does the public record establish about Kettering Adventist Healthcare v. Sandra Collier, et al.?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Kettering Adventist Healthcare v. Sandra Collier, et al. summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.