What was hallucinated

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).

Details

OSC is here.

Sanction teardown · S.D. Ohio, USA · 2026-02-25

Kettering Adventist Healthcare v. Sandra Collier, et al.

What happened

In S.D. Ohio, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

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).

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Contempt Finding; Brief Struck; Monetary Sanction (monetary penalty: 7500 USD.)

Additional detail

OSC is here.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/1574/Kettering_USA_25_February_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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