An Ohio federal judge fines two lawyers $7,500 for AI-fabricated citations, 'the most egregious' Rule 11 violation in his 46 years on the bench

The problem

Kettering Adventist Healthcare (d/b/a Kettering Health Network) sued Sandra Collier and Mary T. Scott in the U.S. District Court for the Southern District of Ohio. Scott, a lawyer herself, appeared both pro se and as former counsel for co-defendant Collier; H. Leon Hewitt appeared as Collier’s current counsel. In their motion to dismiss, a reply in support of it, and a memorandum contra the third-party defendants’ motion, the two relied on case citations that did not hold up: when the court checked them, it found the cited cases either did not exist or stood for nothing like the propositions asserted.

What was built

No system was built or deployed. This is a court-origin AI-governance honest-negative from the attorney-sanction vein. In her January 15, 2026 response to the court’s show-cause order, Scott stated that she used generative AI in research “for preliminary case identification,” adding that “the duty to verify citations rests entirely with counsel. I failed to satisfy that duty here” (source). She conceded she had not “pause[d], reassess[ed], and independently verify[ied] the authority before filing again” the citations, “commonly known as ‘AI hallucinations,’” in the reply (source). The court named no specific product: no ChatGPT, Claude, or otherwise appears in the record, and the violation rests on the duty of candor and Rule 11(b), not on a finding that any particular AI tool was used (source).

The outcome

The predicate finding: at least twelve fabricated or inapposite citations. In its January 2, 2026 Decision, recounted in the sanction order, the court found that “Scott cited at least twelve cases that either do not exist or do not remotely stand for the purported propositions of law” (source). Even after Kettering put them on notice, the two “cited those very same cases for the very same propositions of law in their later Reply” (source).

The sanction: $5,000 against Scott and $2,500 against Hewitt, a combined $7,500. On February 25, 2026 (Doc. #122), the court found both attorneys in contempt and in violation of Rule 11(b) and, pursuant to Rule 11(c), imposed the fines “payable to the Clerk of Court within thirty (30) days of entry” (source). The court set the combined figure against the “in excess of seventy-five hours” it had spent on the issue, calling “$7,500, $100 per hour that the Court spent addressing this issue,” “more than reasonable to address the harm and resultant reallocation of judicial resources” (source).

The characterization: the most egregious Rule 11 violation in forty-six years. The court called the filings “the most egregious violations of Rule 11 the undersigned has seen in his forty-six years on the federal bench,” reported the conduct to the Supreme Court of Ohio Office of Disciplinary Counsel, struck the motion to dismiss without prejudice to refiling, and recused (source). As the ABA Journal reported, Rice “imposed a collective sanction of $7,500 against two attorneys for AI hallucinations” and “found them in contempt and referred them to the Ohio Supreme Court’s Office of Disciplinary Counsel for ‘the most egregious violations of Rule 11’ that he’d seen on the bench” (source). LexisNexis’s Mealey’s reported the same finding of contempt, the $7,500, and the disciplinary referral (source).

Guards against conflation. The $7,500 is the combined figure, not a per-attorney amount (source). No AI product is named, so coverage attributing the citations to “ChatGPT” is unsupported by the record (source). The “forty-six years on the federal bench” span dates Rice’s federal appointment in 1980; a separate reference to service “since 1969” counts his earlier state judgeship, so the two spans describe the same judge, not a discrepancy (source).

How this was verified

This case carries a green badge under TIN’s current standard: independently validated by TIN against the public record. On 2026-08-15 the full text of the February 25, 2026 sanction Order (Doc. #122) was retrieved and extracted, and every figure on this page, the $5,000 and $2,500 sanctions, the $7,500 combined total, the seventy-five-plus hours at $100 each, the thirty-day term, the “at least twelve” citations, the “forty-six years” line, the contempt and Rule 11(b) findings, the disciplinary referral, and the recusal, was matched to the order’s own words. Two mutually independent newsrooms, the ABA Journal (via ALM/Law.com) and Mealey’s (LexisNexis), independently carry the sanction, the contempt finding, and the referral. The honest limit: the figures here are the sanction as imposed on February 25, 2026; whether the attorneys paid, and any later reconsideration or appeal, are docket-only questions that do not disturb the amounts the court ordered, and no claim on this page asserts otherwise.

Related case files

Judge Rice anchored the $7,500 explicitly to the sanctions range in Wadsworth v. Walmart, where the Wyoming court fined the drafting and co-signing attorneys $3,000 and $1,000; he cited that case as the benchmark and then sanctioned “at the top end of the range.” The same duty-to-verify failure, at a smaller scale, drove the $2,000 fine and mandatory generative-AI CLE in Gauthier v. Goodyear. At the far end of the same curve sits Lacey v. State Farm, where a special master imposed $31,100, showing how sharply the penalty scales with the volume of fabrication and the size of the firm.

Sources

Cited in this case file. Tier 1 = primary court record; Tier 2 = independent press naming the parties. Each figure was checked against the live source on 2026-08-15.

1. U.S. District Court, S.D. Ohio, “Order… Imposing Monetary Sanctions of $5,000.00 Against Scott and $2,500.00 Against Hewitt,” Kettering Adventist Healthcare v. Collier, No. 3:25-cv-273, Doc. #122, 2026-02-25 (Tier 1, primary court order, full text extracted). https://websitedc.s3.amazonaws.com/documents/Kettering_USA_25_February_2026.pdf
2. ABA Journal, “Sanctions ramping up in cases involving AI hallucinations,” 2026 (Tier 2, independent, relaying ALM/Law.com; carries the $7,500, contempt, and disciplinary referral). https://www.abajournal.com/news/article/sanctions-ramping-up-in-cases-involving-ai-hallucinations
3. Mealey’s (LexisNexis), “Judge Says AI Conduct Led To ‘Most Egregious’ Rule Violations Ever Seen,” 2026 (Tier 2, independent; carries the contempt finding, $7,500, and referral). https://www.mealeys.com/mealeys/mealeys-artificial-intelligence/articles/2447192/judge-says-ai-conduct-led-to-most-egregious-rule-violations-ever-seen