Ohio

Court - Judge Name

Effective Date

 Applicable To  Categories

Summary

N.D. Ohio – Judge Pamela A. Barker   10/30/2025  Generative AI Generative AI Usage  In Safe Choice, LLC v. City of Cleveland, 2025 U.S. Dist. LEXIS 214410 (N.D. Ohio Oct. 30, 2025), the plaintiff’s opposition to the defendant’s motion for judgment on the pleadings included “four non-existent cases” and “seven misrepresented cases.” During the hearing on the court’s order to show cause, the plaintiff’s attorney included the same seven citations in a “final” brief submitted to the court and reasserted that the originally cited cases were accurate but included hallucinated quotations. The court found sanctions against the plaintiff’s attorney were appropriate because she “has not ‘been scared straight’ . . . because she has not even complied with her own stated objective of ‘adher[ing] strictly to the highest standards of accuracy going forward” and wasted the court’s and opposing counsel’s resources. In assessing the appropriate amount, Judge Barker believed that “sanctions below $6,000 are not adequate to deter attorneys from haphazardly using AI tools to craft legal arguments.” As such, the plaintiff’s attorney was required to pay $7,500 as a penalty to the Clerk of Courts and send copies of this opinion, the court’s order to show cause, and the opposition brief to the Cleveland Metropolitan Bar Association’s Certified Grievance Committee, the plaintiff, and the state court. The court noted that failure to comply with these directives could result in additional sanctions.
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Attorneys/Law Firms
Hamilton County Court of Common Pleas   10/19/2025 Any AI Any AI Usage In Serafin v. Dep’t of State, No. 4:25-cv-00255-JMB (E.D. Mo. Oct. 16, 2025), the court briefly discussed the plaintiffs’ inclusion of citations to “non-existent” cases in their opposition to the defendants’ motion to dismiss. In granting the defendants’ leave to refile its motion to dismiss for lack of venue, Judge Autrey warned that the plaintiffs must cite to “specific (actual) case authority and evidence” in any brief following the newly filed motion. Id. at 18-19.
Requires Disclosure and/or Verification
Suggests Cautious Use of AI
Applies to AI Used for Filings/Drafting
 S.D. Ohio – Magistrate Judge Chelsey M. Vascura  9/11/2025 Generative AI  Generative AI Usage In Bradley v. Eichhorn, 2025 U.S. Dist. LEXIS 177960 (S.D. Ohio Sept. 11, 2025), the pro se plaintiff’s complaint included hallucinated citations to support the plaintiff’s claim for unlawful search and seizure. The court “suspect[ed] that Plaintiff’s inaccurate case citations may be the result of [GenAI]” and warned the plaintiff that he could face sanctions for including hallucinated or unsupported authority in future filings.
Suggests Cautious Use of AI
Applies to AI Used for Filings/Drafting
 S.D. Ohio – Judge Jeffrey P. Hopkins  8/20/2025  Generative AI  Generative AI Usage In Lahti v. Consensys Software Inc., 2025 U.S. Dist. LEXIS 161693 (S.D. Ohio Aug. 20, 2025), the defendant identified “fictitious case citations” in the pro se plaintiff’s reply brief in support of her objections to a magistrate judge’s report and recommendation. Judge Hopkins noted those fictitious cases, and also found that the plaintiff cited fictitious cases in her objections brief. Judge Hopkins then clarified that the conduct “is still sanctionable,” even though the court struck the reply brief as unauthorized by the Federal Rules of Civil Procedure. However, the court decided not to impose sanctions in this case, and instead cautioned the plaintiff that “she will face severe sanctions…likely including monetary sanctions” if any other filing contained false citations.
Suggests Cautious Use of AI
Applies to AI Used for Filings/Drafting
12th District, Ohio Court of Appeals   7/7/2025  Generative AI  Generative AI Usage In Smith v. Gamble, 2025 Ohio App. LEXIS 2317 (Ohio App. Ct. July 7, 2025), the appellant moved to strike the appellee’s brief for including “phantom cases and inappropriate, inaccurate citations” in violation of Rule 11 of the court’s Local Rules (which require parties to submit accurate legal authority). Although the court declined to strike the brief, as the arguments asserted in the brief were necessary to address the appellant’s claims on the merits, Judge Piper concluded that the pro se appellee in fact cited to hallucinated authority and granted the appellant’s motion for sanctions, ordering the appellee to pay attorney’s fees, expenses, and costs associated with the search for the non-existent authority.
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Parties
Common Pleas Court, Cuyahoga County – Judge Russo  3/26/2024   Generative AI Generative AI Usage The court's local rules require attorneys to file a certification attesting that either no portion of any filing will be drafted by generative artificial intelligence or that any language drafted by generative artificial intelligence will be checked for accuracy. The court supplies a template certificate for attorneys to use. 
Requires Disclosure and/or Verification
Applies to AI Used for Filings/Drafting
N.D. Ohio – Judge Boyko   12/31/2023  Any AI   Any AI Usage  The standing order prohibits the use of AI in the preparation of any filing, but specifically exempts legal and internet search engines such as Westlaw and Google. The title of the order, “Court’s Standing Order on the Use of Generative AI,” suggests the order is limited to generative AI, but the text of the order makes no such limitation. The use of the phrase “preparation” could indicate the order also prohibits  the use of AI tools in any part of the preparatory process, including research.
Prohibits Use of AI
Applies to AI Used for Research
Applies to AI Used for Filings/Drafting
S.D. Ohio - Judge Michael J. Newman 7/14/2023  Any AI Any AI Usage  Judge Newman includes identical rules on AI usage in both his civil and criminal standing orders. The orders broadly forbid any party or attorney from “us[ing] Artificial Intelligence (‘AI’) in the preparation of any filing submitted to the Court.” The orders clarify that the court “does not intend this AI ban to apply to information gathered from legal search engines.” However, the orders refer to “AI” generally and are not limited to generative AI.
 Prohibits Use of AI
 Applies to AI Used for Filings/Drafting