Kettering Adventist Healthcare, d/b/a Kettering Health Network v. Sandra Collier, et al.
The case
Kettering Adventist Healthcare, d/b/a Kettering Health Network v. Sandra Collier, et al., Case No. 3:25-cv-273 (S.D. Ohio, Western Division at Dayton), contempt and sanctions order (Doc. 122) filed February 25, 2026, signed by Judge Walter H. Rice. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-129-kettering-v-collier.pdf`. Source URL: https://www.damiencharlotin.com/documents/1574/Kettering_USA_25_February_2026.pdf
What happened
Attorney Mary T. Scott admitted she used generative AI "for preliminary case identification" and mistakenly believed the tools were reliable, filing a motion to dismiss and reply containing AI hallucinations, including a fabricated quotation attributed to Kenty v. Transamerica Prem. Ins. Co. She did not verify the citations before filing, and after Kettering flagged the errors she cited the same fabricated cases for the same propositions again. Attorney H. Leon Hewitt, Collier's counsel, signed a memorandum containing the fabricated citations without independently verifying them. After promising the court they would verify citations going forward, both filed mediation statements containing more misstatements and mischaracterizations of the law.
The rule and the sanction
The court found Scott and Hewitt in contempt and in violation of FRCP 11(b), and noted a violation of Ohio Rule of Professional Conduct 3.3(a)(1). Sanctions imposed: Scott was assessed $5,000 and Hewitt $2,500, a combined $7,500, payable to the clerk of court within 30 days of entry; Collier and Scott's motion to dismiss was stricken without prejudice to refiling before the successor judge with accurate citations; the court referred both attorneys' conduct to the Supreme Court of Ohio Office of Disciplinary Counsel; and the judge asked the chief judge to determine whether further contempt sanctions are necessary, then recused himself and requested reassignment.
How it could have been avoided
(a) AI for "preliminary case identification" still requires verifying every case before it reaches a filing; unreliable-for-any-purpose tools must not feed briefs directly. (b) After an opponent flags fake citations, stop, verify, and correct before filing anything else; re-citing them compounds the violation into contempt. (c) Signing attorneys must check citations even when joining a case late or acting as co-counsel; verification duty is nondelegable.