Quandel Construction Group, Inc. v. Hunt Construction Group, Inc.
U.S. District Court, Southern District of Ohio · S.D. Ohio · Ohio bar guidance
Conduct
Defendant's counsel filed a brief with two incorrect case names, two incorrect citations, and quotations attributed to a case that did not contain them; AI use was disputed.
Consequence
All three of the defendant's attorneys ordered to submit individual sworn statements explaining their roles and the cause of the errors.
Lesson
Marbley: the Rule 11 reasonable-inquiry duty applies whether or not AI was used; the sworn-submission remedy builds a record for possible discipline.
Verified May 14, 2026
- Citation
- Quandel Constr. Grp., Inc. v. Hunt Constr. Grp., Inc., No. 2:24-cv-02362 (S.D. Ohio Mar. 31, 2026) (Marbley, C.J.)
- Decided
- March 31, 2026
Summary
Counsel for defendant Hunt Construction Group filed an opposition memorandum that contained two incorrect case names, two incorrect case citations, and direct quotations attributed to a case that did not contain the quoted language. The worst of it was a citation to "Aerpio" with the wrong case name, wrong docket number, and wrong reporter cite; Hunt had meant to cite Aerpio Pharmaceuticals, Inc. v. Quaggin, 2019 WL 4717477 (S.D. Ohio Sept. 26, 2019), and of the three quotations it drew from the case, only the phrase "inextricably intertwined" actually appears there. Plaintiff's counsel hypothesized that the errors were a generative-AI hallucination; Hunt's counsel denied using AI and sought leave to file a corrected brief. Chief Judge Algenon L. Marbley wrote that "[i]t does not appear that artificial intelligence was the culprit," but found that Hunt had still failed to explain how the errors occurred.
- AI tool:
- Disputed (defendants' counsel denied using generative AI; plaintiff's counsel hypothesized a GenAI hallucination; the court declined to make a formal AI-use finding)
What sanction did the court impose?
The court granted Hunt leave to file a corrected brief and denied Quandel's underlying motion for relief from stay on other grounds. On the citation errors, it ordered all three of Hunt's attorneys, Peter W. Hahn, Mr. McNamara, and Ms. Stehle, to submit individual sworn statements explaining their roles in preparing the brief and the cause of the errors. The court emphasized that the Rule 11 reasonable-inquiry duty applies "regardless of whether an attorney utilizes artificial intelligence," and that no filing should contain citations, whether from AI or any other source, that a lawyer has not personally read and verified. It imposed no monetary sanction in this order; the sworn submissions create a record that could support later discipline if inconsistencies surface.
Why does Quandel Construction Group, Inc. v. Hunt Construction Group, Inc. matter for law firms using AI?
Quandel Construction v. Hunt Construction shows AI-style citation problems reaching sophisticated commercial litigation between general contractors, not just pro se filings or solo practitioners. The diagnostic error pattern is the one managing partners should flag in internal review: a citation whose case name, docket number, and reporter cite all disagree with each other, paired with quoted language that does not appear in the real opinion the citation roughly points to. A two-minute Westlaw or CourtListener pull on any one of those three identifiers would have caught the fabrication before filing.
Chief Judge Marbley’s reasoning is the part worth keeping. He declined to find that AI caused the errors, then held that it did not matter. The Rule 11 reasonable-inquiry duty applies whether or not an attorney used AI, so the AI-or-not question is not dispositive of the sanctions analysis. The remedy followed that logic: rather than fees, the court ordered each of Hunt’s three attorneys to file an individual sworn statement explaining the cause of the errors. That is procedurally lighter than a monetary sanction, but it creates a sworn record that can support later discipline if the statements do not line up. The opinion’s “any other source” language also extends the verification duty past AI-specific scenarios, which makes Quandel useful authority in ordinary citation disputes as well.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Marbley's holding that Rule 11 reasonable-inquiry duties apply 'regardless of whether an attorney utilizes artificial intelligence' is clean authority for the proposition that the AI-or-not question is not dispositive of the sanctions analysis. Counsel responding to a suspected-AI accusation should not assume that denying AI use ends the inquiry.
- The sworn-submission remedy is procedurally lighter than fees but creates a sworn record. Counsel responding to a similar order should treat the submissions with deposition-level care, since inconsistencies between them can themselves become disciplinary issues.
- Marbley's line that no filing should contain citations, 'whether provided by generative AI or any other source,' that a lawyer has not personally read and verified is useful language for citation-discipline arguments. The 'any other source' qualifier extends the verification duty beyond AI-specific scenarios.