Kettering Adventist Healthcare v. Sandra Collier, et al.
S.D. Ohio · Feb 25, 2026
- Jurisdiction
- federal
- Court
- S.D. Ohio
- Record ID
- kettering-adventist-healthcare-v-sandra-collier-et-al-2026-02-25
- Observed outcome
- Contempt finding, motion to dismiss stricken without prejudice, and $7,500 in total monetary sanctions.
- Known monetary consequence
- $7,500
Why this matter warrants attention
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.
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).
Ten bad citations in one brief drew $7,500 plus contempt — cap any brief's citations until a second attorney signs off.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Contract
- Trial
- Monetary
- AI attribution
- Admitted
- Recorded tool
- Generative artificial intelligence (unspecified)
- Known monetary consequence
- $7,500
- 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.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Counsel admitted to using generative AI for research.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Assign a responsible reviewer for AI-assisted research and drafting.
- Retain a matter-level record of source checks and corrections.