State v. Coleman

Citations

• 2026 Ohio 965

Syllabus

CIVIL - sanctions; attorney representing criminal defendant in application to reopen; use of hallucinated artificial intelligence quotes from transcript; fabricated quotations; public artificial intelligence platform; ChatGPT; quotes do not exist; hearing held before appellate panel; admission of misconduct; staff member; paralegal; use of improper artificial intelligence tools; failure to review submission; impugn prosecutor; improper challenge to appellate counsel's effectiveness; claimed remedial measures; continuing education; intra-firm policy; policy had hallmarks of artificial intelligence; appeal to Supreme Court; after sanction hearing respondent used artificial intelligence in a Cuyahoga County criminal case; prosecutor identified improper use; alleged inadvertence; post-hoc action of similar misconduct; inherent judicial authority; control abuse of judicial process; constitutional authority; statutory authority to guard against contempt; Ohio App.R. 23; Ohio Rules of Professional Conduct; candor toward the tribunal; false statements of fact; responsibilities regarding nonlawyer assistance; dishonesty; fraud; misrepresentation; deceit; conduct prejudicial to administration of justice; failure to take corrective action; court not bound by private settlement agreement; court need not defer only to disciplinary process; service of judgment upon courts; verification requirements for future filings; mandatory continuing legal education requirements; strike original application to reopen; removal of respondent as counsel; written apologies to those defamed by fabricated filing; compliance and enforcement conditions.