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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Kettering Adventist Healthcare v. Sandra Collier, et al.
S.D. Ohio · Feb 25, 2026
OH / federalEditorial impact: mediumfake citationsfabricated quotesmisrepresented authoritycontract
Direct answer
What happened in this matter?
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). Outcome: Contempt Finding; Brief Struck; Monetary Sanction. OSC is here.
- 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
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). Outcome: Contempt Finding; Brief Struck; Monetary Sanction. OSC is here.
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
AI
AI toolAI (implied, unspecified)
Party typeLawyer
OutcomeContempt Finding; Brief Struck; Monetary Sanction
Known amount$7,500
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Contempt Finding; Brief Struck; Monetary Sanction
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.?
- 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). Outcome: Contempt Finding; Brief Struck; Monetary Sanction. OSC is here.
- 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.