Published opinion, 26 May 2026 · source · PDF · 23 pages
1990),” for the proposition that any challenge to the validity of a foreign judgment must be directed to the originating jurisdiction, which in this case would be the courts in Tennessee. Meade asserted, however, that the citation was incorrect, and despite soliciting the help of the law librarian, it could not find the case. Meade also provided three other cases cited by Guo that contained incorrect citations and could not be found.
Meade also provided three other cases cited by Guo that contained incorrect citations and could not be found. Meade postulated that the cases were “wholly fictitious.” {¶ 16} On July 10, 2025, Guo opposed Meade’s request for sanctions. He stated in his motion that Davis v.
Ct. App.),” a case which this court could not locate. The trial court denied Guo’s motion on July 22, 2025. {¶ 20} The trial court held a hearing on the motions for sanctions on August 4, 2025.
C. The trial court did not abuse its discretion in denying Guo’s motion to set aside the sanctions against him where he cited and relied upon five different AI-hallucinated cases. {¶ 57} Finally, in his fourth assignment of error, Guo argues that the trial court abused its discretion when it sanctioned him for including mis-citations in his filings to the court. Again, Guo appeals the trial court’s denial of his Civ.R.
He further provided alleged quotations from all the cases except for Davis. The cases, however, do not exist at those citations. 22.
In all respects, they appear to be the result of AI-generated hallucinations. Furthermore, contrary to his claim on appeal, when Guo was confronted with these mis- citations, his response was to affirm that the citations existed and to chastise Meade’s attorney for not performing “due diligence” or making “a genuine effort to research these authorities.” {¶ 61} Ohio courts have imposed sanctions under their inherent authority where parties have submitted “hallucinated” case citations such as those submitted by Guo. See Gamble v.
Gamble, 2025-Ohio-2381, ¶ 27 (12th Dist.); see also State v. Coleman, 2026- Ohio-965 (11th Dist.) (imposing sanctions for using AI hallucinated transcript quotations). It is no defense that Guo is a pro se litigant with limited availability to Ohio- specific legal resources as “[i]t is well established that pro se litigants are presumed to have knowledge of the law and legal procedures and that they are held to the same standard as litigants who are represented by counsel.” State ex rel.
Mengel, 2003-Ohio-6448, ¶ 10. Guo had an obligation to verify that the cases and law he was presenting to the court were real and not a fabrication. Guo, therefore, has not demonstrated a meritorious defense to the claim that he should be sanctioned for providing hallucinated citations to the trial court.