Vision Management Group, LLC v. Constant Aviation, LLC
U.S. District Court, Northern District of Ohio · N.D. Ohio · Ohio bar guidance
Verified May 5, 2026
- Citation
- Vision Mgmt. Grp., LLC v. Constant Aviation, LLC, No. 1:25cv00052, 2025 WL 2695801 (N.D. Ohio Sept. 22, 2025) (Barker, J.)
- Decided
- September 22, 2025
Summary
In an order granting Constant Aviation's motion to dismiss, U.S. District Judge Pamela A. Barker disregarded a citation to a purported Sixth Circuit decision, "Onyx Enters. Int'l Corp. v. Sloan, 843 F. App'x 859, 867 (6th Cir. 2021)," that plaintiffs' counsel offered for the proposition that a duty in tort may arise separately from contractual obligations where professional services are involved. The court reported that "[d]espite many attempts," it could not locate the case by name or by the Federal Appendix citation provided; a search of the case name returned only unrelated district court decisions out of Colorado and the Southern District of Florida. The court also flagged a separate inaccurate pinpoint citation to Cook v. Ohio National Life Ins. Co. (wrong reporter page and a non-existent page 862). Judge Barker did not impose a monetary sanction but reminded counsel of their Rule 11 duties and duty of candor, citing Park v. Kim, Wadsworth v. Walmart, and Mavy v. Commissioner of Social Security as precedent on AI-hallucinated and fake citations.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction. The court disregarded the apparently fabricated Onyx Enterprises citation and the underlying argument it supported, expressly reminded plaintiffs' counsel of obligations under Fed. R. Civ. P. 11 and the duty of candor, and admonished counsel to ensure accurate citations. Defendant's motion to dismiss was granted in full and leave to amend was denied.
Why does Vision Management Group, LLC v. Constant Aviation, LLC matter for law firms using AI?
Vision Management is a useful counter-example to the assumption that a court must impose a fine for AI-style fabricated citations to matter. Here the merits ruling did the work: the unsupported authority was discarded, the argument it propped up collapsed, and the case was dismissed with prejudice. For a managing partner, the operational lesson is that “no sanction” cases still produce reportable client harm. Plaintiffs lost on a dispositive motion in part because their counsel cited an opinion that does not exist, and the published order names counsel and points to Rule 11 jurisprudence on fake citations, which is a footprint a malpractice carrier or opposing counsel can find with one search.
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.
- The court did not expressly attribute the fabricated Onyx Enterprises citation to generative AI; the AI-hallucination inference is implied from the pattern (non-existent Fed. Appx. citation, fake pinpoint to Cook) and from the court's choice of Rule 11 authorities, which all involved AI-generated fake authorities.