Safe Choice, LLC v. City of Cleveland
The case
Safe Choice, LLC v. City of Cleveland, No. 1:24-cv-02033-PAB (N.D. Ohio), sanctions order filed October 30, 2025, reported at 2025 WL 3029553. Federal district court. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-103-safe-choice-v-cleveland.pdf`.
What happened
Attorney Arleesha Wilson filed a brief containing four nonexistent cases and seven real cases misrepresented (each twice), bearing hallmarks of generative AI use. In her show-cause response she included additional fabricated quotations, and the court inferred she had continued using AI-generated material without adequate verification.
The rule and the sanction
Rule 11(b), Federal Rules of Civil Procedure. The court imposed a $7,500 penalty payable to the Clerk, ordered Wilson to serve the order on the Cleveland Metropolitan Bar Association's grievance committee and on her client, and ordered her to file the materials in state court after remand.
How it could have been avoided
(a) Verify every citation exists and says what is claimed before filing; "my law clerk supplied it" is not verification, the court called Wilson's attempt to shift the blame to her law clerk "inexcusable." (b) Do not double down in a show-cause response; repeating unverified material compounds the violation. (c) Adopt a firm-wide rule that any AI output used in a filing is cite-checked against Westlaw or Lexis.
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