Kettering Adventist Healthcare v. Collier, No. 3:25-cv-273 (S.D. Ohio 2026)

Case details
Full caption
Kettering Adventist Healthcare v. Sandra Collier, et al.
Country
United States
Jurisdiction
Federal
Court
Southern District of Ohio (S.D. OHIO)
Decided
2026
THE UNITED COURTFOR THE OF OHIOWESTERN DIVISION AT KETTERING ADVENTISTHEALTHCARE, d/b/a KETTERINGNETWORK,Plaintiff/Counter-Defendant,V.SANDRA e?5/.,Defendants/Counter-Plaintiffs,V.BECKER & PC,et al.,Third-Party Case No. 3:25-cv-273Judge Walter H. RiceMag. Judge Caroline ORDER FINDING THAT MARY SCOTT, ESQ., H. LEON HEWITT, ESQ., AREIN OF THIS AND VIOLATED OF CIVILPROCEDURE 11(b), PURSUANT TO RULE 11(c), IMPOSING MONETARYOF $5,000.00 AGAINST SCOTT AND $2,500.00 HEWITT, TOPAID TO OF WITHIN DAYS OF ENTRY;REQUESTING THE CHIEF JUDGE OF THE SOUTHERN DISTRICT OF OHIO TOSANCTION FOR IS MOTION TODISMISS OF SANDRA COLLIER SCOTT (DOC. IS STRICKEN PREJUDICE TO REFILING;SHALL MAKE REPORT TO OF OHIO OFFICE OFDISCIPLINARY COUNSEL; NOTICE OF RECUSAL AND REQUEST THAT CHIEFJUDGE TO JUDGE IN SOUTHERNOF OHIO IN CINCINNATI COLUMBUS SEAT OF COURTCase: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 1 of 14 PAGEID #: 2089STATES DISTRICT SOUTHERN DISTRICT DAYTON HEALTH COLLIER, H. Gentry EPSTEIN GREEN, Defendants. T. AND CONTEMPT COURT HAVE FEDERAL RULE AND, SANCTIONS AGAINST BE THE CLERK COURT THIRTY (30) DETERMINE WHETHER CONTEMPT NECESSARY; DEFENDANTS/COUNTER-PLAINTIFFS LEE AND #13) WITHOUT UNDERSIGNED SUPREME COURT REASSIGN CASE ANOTHER DISTRICT THE DISTRICT THE OR
On January 2, 2026, this Court issued a lengthy Decision and Entry detailingmore than a dozen fraudulent citations made by Defendant/Counter-Plaintiff MaryT. Scott, both pro se and as former counsel for Plaintiff Sandra Lee Collier, and/or by H. Lean Hewitt, current counsel forCollier. #113, These fraudulent citations were made byScott in Collier and Scott's Motion to Dismiss (Doc. #13) and Reply in support ofsame (Doc. signed by Scott alone, and Collier and Scott's memorandumcontra the Motion to Dismiss ofThird-Party Defendants Epstein Becker & GreenP.James Jill Bigler, and Christopher Page McGinnis (collectively "EBGDefendants"). (Memo. in Opp., Doc. #93) (collectively "the Filings"). From itsreview of the citations, the Court concluded that Scott and Hewitt had violatedRule 11 's requirement that an attorney signing a filing "certif[y] that to the best ofthe person's knowledge, information, and belief, formed after an inquiryreasonable under the circumstances!,] the claims, defenses, and other legalcontentions are warranted by existing law or by a nonfrivolous argument forextending, modifying, or reversing existing law or for establishing new law "FED.R.CIV.11(b)(2).The Court also noted that, despite being put on notice by Plaintiff KetteringAdventist d/b/a Kettering Health Network ("Kettering") on 15, 2025, that at least three cited cases in the Motion to Dismiss "did not statewhat Collier and Scott represented that they did. Collier and Scott cited those veryCase: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 2 of 14 PAGEID #: 2090Esq., co-Defendant/Counter- Esq., (Doc. PAGEID 2020-26). #69), C., Petrie, P. Healthcare, September
same cases for the very same propositions of law in their later Reply." #113,PAGEID citing Kettering Memo. in PAGEID 1215,1218,1220,nn. 7, Finally, despite Scott and Hewitt having been on notice for more three months and one month, respectively, that they had submitted phantom wholly inaccurate citations, neither Scott nor Hewitt acknowledged theirThe Court that, by failing to do so, Scott and had violated Ohio Rule of Professional Conduct 3.3.(Id. at PAGEID In light of the the Court ordered Scott and Hewitt to show nolater than January why they should not be sanctioned for violatingFederal Rule of Civil Procedure (b) and not be held in contempt of this and why Collier and Scott's Motion to Dismiss should not be overruled withprejudice as PAGEID 2035-36). The Court further indicatedthat, upon resolution of the Show the would refer Scottand Hewitt to the appropriate disciplinary committee and himself further proceedings. (Id. at 2036).On January 15,Scott filed her Response, stating that she usedartificial intelligence ("Al") in "for preliminary caseidentification. At the time, I mistakenly believed those tools were sufficientlyreliable for that limited purpose. . .. of the toot used, the duty to verifycitations rests entirely with counsel. I failed to satisfy that duty here." (ScottResp., PAGEID 2039). She also that made heraware of several inaccurate citations, but that she did not "pause,Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 3 of 14 PAGEID #: 2091(Doc. 2026, Opp., Doc. #44, 9-10). than or transgressions. concluded Hewitt (a)(1). 2026-27) above, cause, 16, 2026, 11 Court, sanction. (Doc. #113, Cause Order, undersigned recuse from PAGEID 2026, generative research Regardless Doc. #114, concedes Kettering reassess, and
independently verify the authority before filing again" using those citations, commonly known as "Al " in Collier and Scott's Reply.(Id.}. She acknowledges that, even though she did not fabricate factual her failure to acknowledge and correct the Al-hallucinated citations in the violated her duty of candor. {Id. at 2039-40).On January 16,Hewitt filed his Response, conceding that, although "Ijoined the case late, [I] failed to independently verify the presented case citations, and that failure fell below the standards of integrity, diligence, and owed to this Court." (Hewitt Doc. #117, He states that fabricated citations were drafted by Scott, but that he erred in relying on citations without verification before appending his name to the memorandumcontra the EBG Defendants' Motion to Dismiss, {/d. at PAGEID remediation, Hewitt intends to engage "additional experienced litigators forindependent review where " (Id. at PAGEID 2047).While Hewitt and Scott were making timely and contrite filings to the Court,including intended affirmative steps to future errors (Doc. PAGEID2040; Doc. #117, PAGEID 2047), the omnibus case was set for mediation beforeMagistrate Judge Silvain, Jr., on January 28, 2026. Judge Order,Doc. #119, 2056).1 On January 21, just days after promising 1 Judge Silvain, "with recognition of the of the proceedings,. .. direct[ed] that this Order be filed under seal." #119, However, Judge Silvain correctly that the "possible for misconduct" to thisCourt's local rule on nondisclosure of mediation statements applies (id., quoting S.D. OHIO Civ.R.Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 4 of 14 PAGEID #: 2092fabricated hallucinations, assertions, Filings PAGEID 2026, law care Resp., PAGEID 2046). the those 2046-47). As appropriate. prevent #114, Peter B. (Mag. PAGEID 2026, the Magistrate sensitive nature mediation (Doc. PAGEID 2058). Magistrate determined sanctions exception
undersigned that they would take affirmative to that all citations infuture filings would be Hewitt and Scott submitted mediation statementsto Magistrate Judge Silvain on behalf of Collier and Scott respectively.#119, Those statements were rife with "patentmisstatements and mischaracterizationsofthe " (Id.}. Consequently,Judge canceled the and referred the tothe undersigned for further (Id. at PAGEID 2071-72).The breadth and depth of Scott and Hewitt's continued malfeasance leavethe Court almost at a loss for words. The undersigned expresses his deepappreciation for Judge Silvain's exhaustive of Scott andHewitt's in their mediation PAGEID2059-71), that discussion by and thediscussion of their citations as follows:Hewitt: Two that do not exist in the citation formatsprovided by Hewitt; (2) Three that are "completely to[Hewitt's] relevant ]" and in no way stand for for which he cites them; and (3) Eight cases that, as citedby Hewitt, "exaggerate[] or misappl[y] the law throughout [Collier's]mediation statement." (Doc. #119, PAGEID 2059-67).Scott: Four unrelated or contrary to the propositions forwhich she cites them; and (2) Five cases for which Scott misstates thelaw. #119, 2067-71).in its January 2, 2026, the observed that and Scotthad relied on v. Prem. Ins. Co. for the proposition 16.3(c)(3)(C)), and the is that the of Al by attorneyspublic the DIRECTS the of Court to the OrderCase: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 5 of 14 PAGEID #: 2093steps ensure accurate, herself, (Doc. PAGEID 2058). law. Magistrate Silvain mediation matter back proceedings. Magistrate discussion misrepresentations statements (Doc. #119, incorporates reference, summarizes (1) cases cases unrelated assertions[, the propositions (1) cases (Doc. PAGEID Notably, Decision, Court Collier Kenty Transamerica that undersigned convinced magnitude misuse requires disclosure. Accordingly, Court Clerk unseal
"[wjhere claims are based on enforceable legal rights, settlement demands privileged." (Doc. PAGEID 2024, quoting Kenty, Ohio 3d 415, 419Collier and Scott Motion to Dismiss, Doc. #13, However, Court further noted that "nothing the purported quoted byCollier and Scott appears in" (/d). Incredibly, despite this admonitionfrom the Court, Scott cited Kenfyfor that very same proposition in her mediationstatement. (Doc. #119, PAGEID 2068).Magistrate Judge Silvain's Order the Court's previousconclusion: that Scott and Hewitt's fabricated citations constitute the mostinexplicable, and violations of 11(b) by any attorneysthat have ever before the PAGEID 2027-28).despite multiple opportunities since Kettering filed its contra on September 15, for Scott and Hewitt to acknowledge theirit took a lengthy investigation and decision by theCourt before they did so. and worst of all, at the very time Scottand Hewitt were promising the that they would not fabricate the law, they were doing just that in this very to the In sum, Scott and Hewitt's Responses reinforce the Court's conclusionthat they violated both 11(b)(2) and Ohio of Conduct3.3.(a)(1), and that the Court is warranted in imposing sanctions against Scott andHewitt. FED.R.CIV.Also, Scott and Hewitt's misrepresentations Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 6 of 14 PAGEID #: 2094are #113, 72 St. (1995); PAGEID 510). the resembling language Kenty. reinforces egregious, repeated Rule appeared undersigned. (Doc. #113, Moreover, memorandum 2025, transgressions, subsequent Finally, perhaps undersigned cases or misstate case undersigned's colleague. Rule Rule Professional P. 11(c)(1). to
Judge Silvain the to find Scott and incontempt of this "The court has available a variety of sanctions to impose violations, such as striking the offending issuing an admonition, reprimand,or requiring participation in or other educational programs;ordering a fine to the court; referring the matter to authorities!.]" FED.R.CIV.11 advisory cmte. note to 1993am. The that overruling with prejudice Collier and Scott's Motion to Dismissas previously 2035-36), while severe,is still "limited to what suffices to deter repetition of the conduct or conductby others similarly situated." FED.R.CIV.P. 11(c)(4). suchsanction would prejudice Collier, who should not be the Courtorders Collier and Scott's Motion to Dismiss stricken without prejudice to refilingbefore the successor judge with accurate The imposition of sanctions for of generative Al is relatively new;for Mata v. Inc., one of the first significant federal on thewas not published until June 22, 2023. 678 F. Supp. 443 (S.D.N.2023).Westlaw lists Mata as having cited in ^05 since then, reflects the proliferation of generative Al, its infiltration into writing, and itsby The Mata court aptly explains the harmperpetrated by Scott and Hewitt, and why sanctions are appropriate:Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 7 of 14 PAGEID #: 2095Magistrate compel undersigned Hewitt Court. possible for paper; censure; seminars payable [and/or] disciplinary P. Court concludes (Doc. #13), contemplated (Doc. #113, PAGEID comparable However, penalized. Thus, citations. misuse instance, Avianca, cases topic, 3d Y. However, been cases which legal repeated misuse attorneys.
Many harms flow from the submission of fake opinions. Theopposing party wastes time and money in exposing the deception.The Court's time is taken from other important endeavors. The may be deprived of arguments on authentic There is potential harm to the reputation of judges andcourts whose names are falsely invoked as authors of the opinions and to the reputation of a party attributed with conduct. It promotes cynicism about the and theAmerican judicial And a future litigant may be tempted todefy a judicial ruling by disingenuously claiming doubt about itsauthenticity.678 F. Supp. 3d at (footnote The court in Wac/swoth v. Walmart, in imposing monetary sanctions againstthe attorneys who submitted Al-hallucinated noted that, by 24,the date of publication, "[i]t is .. . well-known in the community that Alfake cases." 348 F.R.(D. Wyo. 2025). As evidencedby in 61 cases by the time andScott filed the Motion to Dismiss in August every licensed attorney knew should have known that relying on Al for likely in a filing Al of subsequentciting Mata and Wadsworth reinforce this Court's that theof is rapidly and isone of the facing civil theJanuary 2026, Decision that the expectation of accuratecitations has no exception for generative Al.have monetary sanctions for filing Al-hallucinated citations ranging $1,000 and $5,F.R.D.8Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 8 of 14 PAGEID #: 2096client based judicial precedents. bogus fictional legal profession system. 448-49 omitted). caselaw, February 2025, legal resources generate D. 489, 497 Wadsworth being cited since publication, Collier 2025, or reasonably generative research would result containing hallucinations. The volume cases conclusion: problem attorneys submitting hallucinated citations worsening, biggest threats currently federal litigation. Importantly, 2, made clear Court's Courts imposed attorneys between 000. Wadsworth, 348
at cases), In imposing $3,000 and $1,000 fines on the and co-signing attorneys, the court that bothattorneys were "forthcoming, and apologetic about their Theyalso took steps to the situation prior to the potential sanctions!.]" However, the attorneys were also "attorneys at a prominentnational law firm with presumably deep resources" and access to Lexis Westlaw. For the drafting the court also "the number ofin the filing to real cases" and "the fact on of Al's issues in cases quite some time." Id. at 498.As discussed in the Court's January 2, Decision, Scott cited at leasttwelve cases that either do not exist or do not remotely stand for the purportedof law. (Doc. PAGEID 2021-26). The volume of fabricatedcitations rendered the Court unable to discern "whether [any of the cited byCollier and Scott] exist at all and have any relevance whatsoever to the argumentCollier and Scott are making." [Id. at PAGEID 2029). Nothing in Scott's responsecauses the Court to alter this conclusion. Moreover, unlike in Wadsworth, Scottdid not notify the Court of her errors prior to the of the Show Causeit that, after being notified by of thenonexistent or inaccurate citations in Collier and Scott's Motion to Dismiss, Scottrecited at least three fabricated citations for the exact same incorrect propositionsin their PAGEID 2026). and most importantly, ScottCase: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 9 of 14 PAGEID #: 2097497 (collecting 498. drafting respectively, i/yacfsworth noted honest, conduct. remediate issuance of or Id. attorney, considered hallucinated cases compared that attorneys have been notice generative hallucinating for 2026, propositions #113, cases issuance Order. Rather, bears repeating even Kettering Reply. (Doc. #113, Finally,
now the law four times-b\/ the EBGDefendants, the and Judge Silvain, case that is barely six months though neither nor the EBG Defendants specificallymoved for sanctions with to Scott and Hewitt's fabrications andmisstate nts, among the "harms that flow the submission of fakeopinions" is that "[t]he Court's time is taken from endeavors."Wadsworth, 348 F.R.at 498 (internal quotation omitted), quoting Mata,678 F. Supp. at 448; see Mezu Mezu, 267 Md.354, 370 (Md. Ct. App.2025) (Counsel fake opinions "also this to time totry to find the cases in party's] research how othercourts have dealt with situations involving similar attorney resources pressing work."). Since November 13, 2025, whenthe EBG filed their reply memorandum detailing Scott and misconduct #97), the Court has spent in excess of seventy-five addressing this specific issue. In the factors in this case in ofa sanction at the top of the range discussed in Wadsworth. Thus,the a of $5,to theClerk of Court within thirty days of In a fine of $1,against the the Wadsworthcourt that, he was significantly less than the draftingattorney, the co-signing attorney still Rule 11 by the filing with10Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 10 of 14 PAGEID #: 2098has been caught misstating Kettering, undersigned, Magistrate respectively-in a old Finally, even Kettering respect me from other important D. marks 3d also v. App. submitting required Court take fake cited [the brief, and then misconduct, diverting judicial from other Defendants Hewitt's (Doc. hours sum, weigh favor imposing end Court imposes monetary sanction 000 against Scott, payable (30) entry. imposing 000 co-signing attorney, noted although culpable violated signing
fabricated citations. 348 F.R.D. at 498. The court further concluded that the attorney his "nondelegable duty to ensure a is supportedby law." Id. Here, not appeared in the case Scott filedCollier and Scott's Motion to Dismiss and Reply memorandum containing hallucinated citations. Nonetheless, had he read Kettering's memorandum Collier and Scott's Motion while getting up to he would found about the and could and the Court. At theleast, would have known to check the cases by Scott carefully beforethe memorandum EBG Defendants' to Dismiss (Doc.by signing without doing Hewitt violated both Rule 11 and hisduty to Collier-a client who, unlike the co-signing attorney inhe independently of the drafting Scott.Moreover, Hewitt also did not inform the Court of his transgression prior to Court's January 2, representations to the on January 16, 2026and despite the importance of the mediation to resolvingthe case for Collier, Hewitt could not even be bothered to check whether the caseshe cited existed, much less whether his citations were Accordingly, Court imposes a sanction of $2,500, payable to the Clerk of Court within thirty (30)of entry. combined sanction of $7,500-$100 that thethis issue-is than reasonable to address the harmand resultant reallocation of judicial 11Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 11 of 14 PAGEID #: 2099co- signing violated motion existing Hewitt had when the contra speed, have out phantom citations have alerted Scott very he cited signing contrathe Motion #93); so, nondelegable Wadsworth, represented attorney, the 2026, Decision. Finally, despite Hewitt's Court (Doc. #117), statement accurate. the days The amount per hour Court spent addressing more resources.
As discussed the Rules Advisory contemplated"referring matter to disciplinary authorities" a sanction for violating Rule11. FED.R.CIV.P. 11 to Scott and Responsesto the Show Cause do to the Court's previous conclusion: thatCollier and Scott's Motion to in support of andmemorandum contrathe Defendants' Motion to Dismiss constitute the egregious violations of Rule 11 the undersigned has seen in forty-six years onthe bench. Scott and failure to notify the the fabricated citations once Kettering and the EBG them awareconstitutes a clear violation of Ohio of 3.3.(a)(1).Finally, Scott and Hewitt's misrepresentations to Magistrate Judge Silvain-lessthan three weeks after the Court's January 2, Decision-raise concerns as to whether either Scott or Hewitt should remain active members ingood standing in the bar of Court and of the Supreme Court of Ohio.2 Giventhat the State of exercises plenary oversight of the professional conduct of2 Indeed, February 10, 2018, Scott filed a Notice of Supplemental Authority, purportedly"identifying controlling authority supporting the legal propositions already pleaded[.]" (Doc. #118,PAGEID 2049). However, several of cases cited therein at PAGEID 2050-54) are exactsame cases cited Scott or Hewitt in their mediation statements, and that the Magistrate Judgecorrectly concluded were misstatements of law. Even if citations had been accurate,however, of Notice-nearly five months Kettering warned Scott and Collierabout the improper citations in Motion to Dismiss-would have been too little, too late.Additionally, as the instant Order was being finalized, Kettering filed a Notice (Doc. #120) andsupporting documentation (Doc. #120-1) that raise serious concerns as to whether Scott hascontinued to facto represent Collier in violation of this Court's September 19, 2025,Disqualification Order. (Tr., Doc. #63). Notice, Kettering further asserts that Scott madenumerous false representations of and misrepresented propositions of law. at PAGEID2076-78 (citations omitted)). Judge Kettering's any responsemade Scott in evaluating whether further sanction for contempt of court is warranted.12Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 12 of 14 PAGEID #: 2100above, Committee has long the as advisory cmte. note 1993am. Hewitt's Order nothing alter Dismiss, Reply same, EBG most his federal Moreover, Hewitt's tribunal of Defendants made Rule Professional Conduct 2026, grave this Ohio on the (id. the by the all the timing the after their de In its fact [Id. The Chief may consider Notice and by
attorneys admitted in OHIO R.PROF.COND. 8.5(a), the undersigned concludesthat the Supreme Court of Office of Disciplinary Counsel ("ODC") is best-equipped to handle violations of Ohio rules. Consequently, the Court will referScott and Hewitt's conduct to the ODC.For the reasons, and Hewitt ARE FOUND to be in contemptof this Court and FOUND to have violated Rule 11 Pursuant to 11 (c),Collier and Scott's Motion to Dismiss #13) is PREJUDICE to is ASSESSED a monetary sanction of $5,000, andis ASSESSED a monetary sanction of $2,500, payable to the Clerk ofwithin THIRTY (30) days of REQUESTS that the Chieffor the Southern District of determine whether sanction for contemptof Court is necessary beyond what the undersigned Rule 11. Courtshall the ODC of Scott and Hewitt's conduct letter, enclosing copies of:(a) the 2026, Decision; (b) Magistrate February 19, 2026,Order; and (c) the instant Orderundersigned hereby RECUSES proceedings in thisThe undersigned further REQUESTS that the Judge reassign thecaptioned case to another District within the Southern District of Ohio inthe Cincinnati or Columbus seat of court.33 February 24, 2026, Kettering filed a for Status Conference to address, amongissues, "[t]he of this Court's reassignment of this matter to another District Judge."(Doc. #121, PAGEID 2086). The undersigned concludes that Motion is best addressed by thesuccessor judge.13Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 13 of 14 PAGEID #: 2101Ohio, Ohio's the foregoing Scott ARE (b). Rule (Doc. STRICKEN WITHOUT refiling, Scott Hewitt both Court entry. The Court Judge Ohio under The notify via January 2, Judge Silvain's The himself from further matter. Chief Judge On Motion Video other timing the
IT IS SO ORDEREDFebruary 25, ^r i^ ^WALTER RICE, UNITED COURT14Case: 3:25-cv-00273-WHR-CHG Doc #: 122 Filed: 02/25/26 Page: 14 of 14 PAGEID #: 2102LJ" H. JUDGE 2026 STATES DISTRICT
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