Ohio · state appellate court · 2026

Guo v. Meade Motorcars, L.L.C.

Ohio Court of Appeals, 26 May 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Ohio Ct. App.

  1. Court. Ohio Court of AppealsCOURT
  2. Level. state appellate courtLEVEL
  3. Date. 26 May 2026DATED
  4. Docket. No. S-25-035DOCKET
  5. Judge. SulekJUDGE
  6. Reporter. 2026 Ohio 1930CITE
  7. Documents. one document, 8 passages quoted belowON FILE
  8. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

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.

What the text mentions

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Where this fits

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More from Ohio Court of Appeals, from Ohio, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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