Kettering Adventist Healthcare v. Sandra Collier
U.S. District Court, Southern District of Ohio · S.D. Ohio · Ohio bar guidance
Verified May 14, 2026
- Citation
- Kettering Adventist Healthcare v. Collier, No. 3:25-cv-273 (S.D. Ohio Feb. 25, 2026) (Rice, J.)
- Decided
- February 25, 2026
Summary
The court found attorneys Mary T. Scott and H. Leon Hewitt, who represented defendant Sandra Collier, in contempt and in violation of Federal Rule of Civil Procedure 11(b) after their filings contained more than a dozen fabricated or misrepresented citations. Scott conceded she had used generative AI for "preliminary case identification" without verifying the results. The misconduct included repeatedly citing a real case, Kenty v. Transamerica Premier Insurance Co., for a proposition the opinion does not contain, even after the court flagged the misquotation.
- AI tool:
- generative AI (admitted by counsel for preliminary case identification)
- Sanction amount:
- $7,500
What sanction did the court impose?
The court found Scott and Hewitt in contempt and in violation of Rule 11(b), imposing monetary sanctions of $5,000 against Scott and $2,500 against Hewitt (a combined $7,500), payable to the Clerk of Court. The court struck Collier and Scott's Motion to Dismiss without prejudice to refiling, referred both attorneys to the Supreme Court of Ohio Office of Disciplinary Counsel, and the presiding judge recused himself.
Why does Kettering Adventist Healthcare v. Sandra Collier matter for law firms using AI?
Contempt findings are unusual in the AI-citation sanctions line, which typically resolves through Rule 11 monetary penalties or admonishment. Managing partners should note that misrepresenting a real case’s holding, here citing Kenty v. Transamerica Premier Insurance Co. for a proposition the opinion does not contain, can be treated as more serious than citing a wholly fabricated decision, because it implies the filer mischaracterized authority rather than merely failed to verify it. The escalation to contempt here followed the attorneys repeating the same misrepresentations to a magistrate judge days after promising the court they would not.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.