Safe Choice, LLC v. City of Cleveland
U.S. District Court, Northern District of Ohio · N.D. Ohio · Ohio bar guidance
Verified May 14, 2026
- Citation
- Safe Choice, LLC v. City of Cleveland, No. 1:24-cv-02033-PAB, 2025 WL 3029553 (N.D. Ohio Oct. 30, 2025)
- Decided
- October 30, 2025
Summary
Attorney Arleesha S. Wilson, representing plaintiff Safe Choice, LLC, cited four nonexistent cases and misrepresented the holdings of seven real cases in an opposition brief, then repeated the misrepresentations in a "final" brief presented at a contempt hearing. After Judge Pamela A. Barker issued a show-cause order on October 17, 2025, Wilson responded with a brief that itself contained fabricated quotations from five additional cases, four of them Sixth Circuit decisions. The court found three independent Rule 11(b) violations and concluded Wilson was "still using AI to draft her briefs and failing, whether through indifference or carelessness, to verify the accuracy of the AI-drafted quotes."
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $7,500
What sanction did the court impose?
Sua sponte Rule 11 sanctions: $7,500 penalty payable to the Clerk of Courts within 30 days; mandatory referral to the Cleveland Metropolitan Bar Association's Certified Grievance Committee; service of the sanctions order on the client, Safe Choice, LLC; and an order to refile the sanctions order with the state court upon remand. The court explicitly rejected sanctions below $6,000 as inadequate to deter haphazard AI use.
Why does Safe Choice, LLC v. City of Cleveland matter for law firms using AI?
Safe Choice extends the post-Mata sanctions baseline upward and is notable for two reasons managing partners should track. First, Judge Barker explicitly held that monetary sanctions below $6,000 are no longer adequate deterrence for AI-driven citation failures, signaling that the 2023-era $5,000 figure from Mata v. Avianca is being treated as a floor, not a ceiling. Second, the court treated the response to the show-cause order as itself a fresh Rule 11 violation when it contained new fabricated quotations, illustrating that an attorney’s first reaction to a hallucination finding is now part of the discipline calculus.
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.