N.D. Ohio: Order on the Use of Generative AI and Shadow Counsel (Magistrate Judge Jonatha…
Magistrate Judge Jonathan D. Greenberg · U.S. District Court for the Northern District of Ohio
Verified October 1, 2026
- Citation
- Order on the Use of Generative AI and Shadow Counsel (Magistrate Judge Jonathan D. Greenberg, N.D. Ohio)
- Order date
- February 2026
Summary
'[N]o attorney for a party, or a pro se party, may use generative Artificial Intelligence ("AI") in the preparation of any filing submitted to the Court.'
What does the order require?
- '[N]o attorney for a party, or a pro se party, may use generative Artificial Intelligence ("AI") in the preparation of any filing submitted to the Court.'
- 'Parties and their counsel who violate this AI ban may face sanctions, including, inter alia, striking the pleading from the record, the imposition of economic sanctions or contempt, and dismissal of the lawsuit.'
- The ban does not apply to information gathered from legal search engines such as Westlaw or LexisNexis, but 'does apply to AI Overviews generated by Internet search engines, such as Google or Bing, as these AI Overviews are a form of generative AI.'
- 'All parties and their counsel have a duty to immediately inform the Court if they discover the use of generative AI in any document filed in this case.'
- '[T]o preserve Rule 11 accountability, the Court prohibits any attorney assistance without appearance or disclosure or undisclosed attorney ghostwriting (otherwise known as shadow counsel) in this case.'
Practice areas: federal civil
What the order requires
Magistrate Judge Jonathan D. Greenberg’s Order on the Use of Generative AI and Shadow Counsel (N.D. Ohio) is a form order entered in individual cases. Relying on the Court’s inherent authority and Rule 11, it provides that “no attorney for a party, or a pro se party, may use generative Artificial Intelligence (‘AI’) in the preparation of any filing submitted to the Court.”
The ban does not reach information gathered from legal search engines such as Westlaw or LexisNexis, but it “does apply to AI Overviews generated by Internet search engines, such as Google or Bing, as these AI Overviews are a form of generative AI.” Parties and their counsel who violate it may face sanctions, including striking the pleading, economic sanctions or contempt, and dismissal of the lawsuit. All parties and their counsel must immediately inform the Court if they discover the use of generative AI in any document filed in the case.
The order also prohibits “any attorney assistance without appearance or disclosure or undisclosed attorney ghostwriting (otherwise known as shadow counsel)” in the case, to preserve Rule 11 accountability.
How it changed
The earlier version, whose PDF dates from February 2026, banned “Artificial Intelligence” generally and excluded both legal search engines and Internet search engines “such as Google or Bing” from the ban. The current version, whose PDF dates from June 2026, limits the ban to generative AI, keeps the legal-search-engine exclusion, and brings AI Overviews from Internet search engines within the ban. The shadow-counsel prohibition is the same in both.
Related orders
The ban follows the pattern of Judge Christopher A. Boyko’s standing order and Judge Charles E. Fleming’s standing order in the same district.