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Courts on AI / Self-represented litigants using AI

Lampinen v. Borer

Ohio Court of Appeals, Eleventh Appellate District · State appellate courts · OH · · 2026-Ohio-2769 · No. 2025-L-134 · opinion

Self-represented litigants using AIartificial intelligence tools

The Ohio appellate court sees signs that a self-represented brief relied improperly on AI tools, but it declines sanctions. The court cautions that lack of candor may be sanctionable and refuses to construct arguments for the appellant.

Disposition
The court affirmed dismissal and declined to impose sanctions while cautioning all litigants.

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

Such a practice is suggestive of an improper reliance on artificial intelligence tools and does not represent a good-faith effort to make a coherent argument. {¶21} This court has previously found the imposition of sanctions to be warranted for the misuse of artificial intelligence. See generally State v. Coleman, 2026-Ohio-965 (11th Dist.). However, recognizing that such power should be exercised with “restraint and discretion” we decline to do so in this instance. Chambers v. NASCO, Inc., 501 U.S. 32, 44 (1991). However, all litigants, regardless of their pro se status, are hereby cautioned that a lack of candor in their briefing may lead to sanctions.

Authorities cited in the passage: State v. Coleman, 2026-Ohio-965 · Chambers v. NASCO, Inc., 501 U.S. 32 (1991)

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