State v. Coleman

State v. Coleman, 2026-Ohio-965, 280 N.E.3d 1042 (Ohio Ct. App., 11th Dist.). Primary opinion: https://storage.courtlistener.com/pdf/2026/03/20/state_v._coleman.pdf ; https://websitedc.s3.amazonaws.com/documents/2026-Ohio-965.pdf

In an application to reopen an appeal, respondent's counsel submitted fabricated transcript quotations attributed to the prosecutor. The opinion's factual findings state the quotations "were generated by ChatGPT", the respondent's paralegal had uploaded case materials to ChatGPT, whose hallucinations produced the false quotations.

The court imposed sanctions under its inherent and contempt authority, stating "the sanctions imposed herein are proportionate" to the misconduct: a $2,000 monetary sanction (with credit for the $2,000 already paid to the Ashtabula County Prosecutor's Office under the settlement); referral to the Office of Disciplinary Counsel; removal as Coleman's counsel; written apology letters within 30 days to the people the fabrications implicated; service of the order on Coleman within 14 days with a written explanation, in plain and understandable language, of the misconduct and the reasons for the removal; two years of service of the order on the presiding judge of every court where Norman appears; two years of a signed verification certification on every Ohio filing; at least six hours of AI-focused CLE within 150 days; and the application to reopen stricken, with Coleman given 90 days to file a new application through new counsel or pro se. The case is also notable as an appellate-court sanction for AI-fabricated evidence (transcript quotations), not just case citations.

Never upload raw case materials to a public chatbot, the input becomes hallucination feedstock. Verify every quotation against the actual transcript before it goes into a filing, especially in an application to reopen where credibility is everything. Supervise nonlawyer AI use under Rule 5.3: the lawyer owns the paralegal's ChatGPT output.

• Primary opinion: https://storage.courtlistener.com/pdf/2026/03/20/state_v._coleman.pdf
• websitedc.s3.amazonaws.com: https://websitedc.s3.amazonaws.com/documents/2026-Ohio-965.pdf