Incident Tracker / United States (state)
State v. Coleman, 2026-Ohio-965 (Ohio Ct. App., 11th Dist.)
·Ohio Court of Appeals, Eleventh Appellate District·US-STATESanctions
An Ohio appellate court fined a criminal-appeal attorney $2,000, removed him as counsel, struck his reopening application, and referred him to the Ohio Office of Disciplinary Counsel after his staff's ChatGPT use produced hallucinated quotations. The opinion defends the court's authority to sanction independent of formal bar proceedings.
- Court
- Ohio Court of Appeals, Eleventh Appellate District
- Date
- 2026-03-20
- Who used the AI
- Not recorded
- AI tool
- ChatGPT
- Conduct
- In an application to reopen a criminal appeal, appellant's counsel filed a brief in which a staff member had used ChatGPT, generating hallucinated quotations attributed to the prosecutor that did not appear in the trial transcript.
- Outcome
- Sanctions
- Penalty
- US$2,000
- Regulatory outcome
- Ohio Office of Disciplinary Counsel: The court fined counsel $2,000, removed him as counsel and struck the reopening application, and referred his conduct to the Office of Disciplinary Counsel of the Supreme Court of Ohio. (2026-03-20)
- Status
- Verified against listed sources
- Last checked
- Not separately recorded
What was fabricated or misused
- Two quotations attributed to the prosecutor on pages 2 and 4 of the application to reopen — not in the trial transcript
- An alleged “legally inflammatory” prosecutor statement cited to transcript page 559 — page 559 was the court reporter’s signature page
- An alleged prosecutor statement about a “duty to retreat” — no such statement appeared in the closest transcript passage
What the court said
“The alleged quotations attributed to the prosecutor did not appear in the trial transcript. The statements were entirely fabricated.”
“The fabricated quotations were generated by ChatGPT, a publicly available generative artificial-intelligence platform.”
“When respondent was put on notice that the filing contained fabricated quotations and thereafter took no corrective action—and indeed pursued an appeal of the denial to the Supreme Court of Ohio without disclosing the infirmity—the conduct moved beyond mere negligence.”
“Respondent shall pay a monetary sanction in the amount of $2,000.”
Timeline
- Application to reopen filed with transcript quotations attributed to the prosecutor.
- State moved for sanctions over quotations it could not find.
- Court denied reopening and ordered counsel to show cause on sanctions.
- Counsel admitted a staff member used AI that generated hallucinated quotes.
- Sanctions hearing held before the appellate panel.
- Parties filed a settlement; court said it was not bound by it.
- Court imposed sanctions, removal as counsel and disciplinary referral.
Why this case matters
The Ohio opinion treats fabricated transcript quotations differently from fake cases. The false material was attributed to a prosecutor and could have affected claims about trial counsel, appellate counsel and the trial judge. Compared with Gauthier, the sanction package was wider: a $2,000 fine, referral, removal as counsel, six hours of AI-focused CLE, future filing certifications and apology letters. It is also notable that the court acted despite a private settlement, explaining that disciplinary review did not replace the appellate court's power to protect its own record.
Practice note
A lawyer signing an application to reopen must check transcript quotations against the transcript itself, even when a staff member drafted the filing. The Ohio court's certification terms are a practical checklist: verify legal citations, verify all quotations against originals, verify record support for facts, disclose any generative AI use and personally review the full filing.
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Similar incidents on the record
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- Mezu v. Mezu (Md. App. Ct. 2025), No. 361 Sept. Term 20252025-10-29 · Appellate Court of Maryland · Regulatory referralMaryland's intermediate appellate court referred an attorney to the state Attorney Grievance Commission after his client's brief cited multiple fictitious ChatGPT-generated cases and he conceded he routinely did not rea…
- Robert Dastou v. Kathryn Holmes, No. 2381CV02212 (Mass. Super. Ct.)2025-07-16 · Massachusetts Superior Court · SanctionsA Massachusetts Superior Court sanctioned a defense attorney who used ChatGPT to 'format' filings, producing motions in limine and jury instructions riddled with hallucinated cases, a fake quotation, and a fictitious le…
- Garner v. Kadince, Inc., 2025 UT App 802025-05-22 · Utah Court of Appeals · SanctionsIn the Utah Court of Appeals, petitioner's counsel filed a brief containing ChatGPT-fabricated citations, including a non-existent 'Royer v. Nelson', violating appellate rule 40. The court sanctioned attorney Richard Be…
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “State v. Coleman, 2026-Ohio-965 (Ohio Ct. App., 11th Dist.)”, safelegalai.com/tracker/state-v-coleman (accessed 2026-09-16). Data: CC BY 4.0.