Incident Tracker

State v. Coleman, 2026-Ohio-965 (Ohio Ct. App., 11th Dist.)

sanctions

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.

Date of decision/order

2026-03-20

Court

Ohio Court of Appeals, Eleventh Appellate District

Jurisdiction

US-STATE

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 not found in the cited authorities.

Consequence

USD 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)