Safe Choice, LLC v. City of Cleveland, No. 1:24-cv-02033-PAB (2025)

Case details
Country
United States
Jurisdiction
Federal
Decided
2025
Disposition
Affirmed
SAFE CHOICE, LLC, Plaintiff, v. CITY OF CLEVELAND, Defendants., Slip Copy (2025) © 2025 Thomson Reuters. No claim to original U.S. Government Works.12025 WL 3029553Only the Westlaw citation is currently available.United States District Court, N.D. Ohio.SAFE CHOICE, LLC, Plaintiff,v.CITY OF CLEVELAND, Defendants.Case No. 1:24-cv-02033-PAB|10/30/2025Editor's Note: This decision contains discussion of citationreferences that are incorrect or do not actually exist. Theseinvalid citations appeared in the original court opinion andhave been preserved as written since they are part of theofficial record. Any links to these invalid citations have beenremoved.Attorneys and Law FirmsArleesha S. Wilson, Law Office of Arleesha Wilson,Cleveland, OH, for Plaintiff.Carli R. Young, Michael Joseph Pike, William M. Menzalora,City of Cleveland Department of Law, Cleveland, OH, forDefendant.PAMELA A. BARKER, U. S. DISTRICT JUDGEMEMORANDUM OPINION AND ORDER*1 On October 17, 2025, the Court issued a MemorandumOpinion and Order (the “10/17/25 Order”), in which it orderedcounsel for Plaintiff Safe Choice LLC, Attorney ArleeshaWilson, to show cause why the conduct specifically describedin that Order is not a violation of Fed. R. Civ. P. 11(b).(Doc. No. 29.) On October 24, 2025, Attorney Wilson filedPlaintiff's Response to Court's Show Cause Order. (Doc. No.31.)1 As explained in greater detail below, upon review ofAttorney Wilson's Response, the Court finds that AttorneyWilson violated Fed. R. Civ. P. 11(b) and sua sponte imposessanctions on her pursuant to Fed. R. Civ. P. 11(c) as set forthherein.I. BackgroundThe relevant background is set forth fully in the 10/17/25Order and will not be repeated herein. (Doc. No. 29.) TheCourt presumes familiarity with its previous Orders in thismatter, including the 10/17/25 Order.II. Analysis“If, after notice and a reasonable opportunity to respond, thecourt determines that Rule 11(b) has been violated, the courtmay impose an appropriate sanction on any attorney...thatviolated the rule or is responsible for the violation.” Fed. R.Civ. P. 11(c)(1). “A district court may ‘[o]n its own’ initiatethe sanctions process by ‘order[ing] an attorney...to showcause why conduct specifically described in the order has notviolated Rule 11(b).’ ” Bojicic v. Dewine, 145 F.4th 668, 671(6th Cir. 2025) (quoting Fed. R. Civ. P. 11(c)(3)). A districtcourt may then “impose[ ] Rule 11 sanctions sua sponte” afterordering counsel to show cause under Fed. R. Civ. P. 11(c)(3). Id. (quoting Jones v. Ill. Cent. R.R. Co., 617 F.3d 843, 856(6th Cir. 2010)).A. Attorney Wilson violated Rule 11(b)In the 10/17/25 Order, the Court found that Attorney Wilsonviolated Rule 11 in three separate ways: (1) by citing four non-existent cases in Plaintiff's Opposition to the City's Motion forJudgment on the Pleadings (the “Opposition”) (Doc. No. 19);(2) by misrepresenting the legal significance of seven casescited in Plaintiff's Opposition; and (3) by making the samemisrepresentations in a copy of a “final” brief presented to theCourt at the Contempt Hearing. (Doc. No. 29.) For the reasonsset forth below, Attorney Wilson's Response to the 10/17/25Order does not change the Court's conclusion.1. Regardless of her intent, Attorney Wilson violatedRule 11 when she cited four non-existent cases inPlaintiff's Opposition (Doc. No. 19)Attorney Wilson concedes that that the four non-existentcases first identified in this Court's Order dated September25, 2025 do not, in fact, exist. (Doc. No. 29, PageID #3119(citing Tr. 25:25– 26:2); Doc. No. 31, PageID #3143–44.)Attorney Wilson, however, seems to suggest that she couldnot have violated Rule 11 based on her subjective belief thatthose cases were removed from Plaintiff's as-filed Opposition.(Id.) The Court disagrees.*2 Under Sixth Circuit law, Rule 11 violations “aremeasured against ‘an objective standard of reasonablenessunder the circumstances.’ ” Gibson v. Solideal USA, Inc., 489
SAFE CHOICE, LLC, Plaintiff, v. CITY OF CLEVELAND, Defendants., Slip Copy (2025) © 2025 Thomson Reuters. No claim to original U.S. Government Works.2F. App'x 24, 29 (6th Cir. 2012) (quoting Merritt v. Int'l Ass'nof Machinists and Aerospace Workers, 613 F.3d 609, 626(6th Cir. 2010)). Thus, “Rule 11 sanctions may be imposedregardless of whether an error was made in good or bad faith.”Seither & Cherry Quad Cities, Inc. v. Oakland Automation,LLC, No.23-11342, 2025 U.S. Dist. LEXIS 143941, at *6(E.D. Mich. July 28, 2025).2In accord with Sixth Circuit law, district courts routinelyfind that citation to non-existent authority violates Rule 11regardless of intent. See, e.g., Mavy v. Comm'r of SSA, No.CV-25-00689-PHX-KML (ASB), 2025 U.S. Dist. LEXIS157358, at *19 (D. Ariz. Aug. 14, 2025) (finding Rule 11violation even when “the inclusion of improper citationswas unintentional”); Attaway v. Ill. Dep't of Corr., No. 23-cv-2091-DWD, 2025 U.S. Dist. LEXIS 70842, at *5 (S.D. Ill.Apr. 14, 2025) (noting, in the context of an AI hallucinationcase, that “[c]arelessness, good faith, or ignorance are notan excuse for submitting materials that do not comply withRule 11”).3 Accordingly, regardless of Attorney Wilson'ssubjective intent, the Court finds that her citation to non-existent cases violates Rule 11. (See Doc. 29, PageID #3118(collecting authorities).)2. Attorney Wilson violated Rule11 by misrepresentingthe holdings of seven cases in Plaintiff's OppositionThe Court is likewise not persuaded by Attorney Wilson'sarguments surrounding the seven cases whose findings andholdings she misrepresented in Plaintiff's Opposition. Insteadof conceding her blatant Rule 11 violations, Attorney Wilsondecided to double down.*3 Take her citation to Huffman v. County of LosAngeles, 147 F.3d 1054 (9th Cir. 1998) for example. InPlaintiff's Opposition, Attorney Wilson cited that case forthe proposition that “Courts have repeatedly held wherethe conspiracy involves at least one actor outside thegovernmental entity, the doctrine does not apply.” (Doc. No.19, PageID #224.) As the Court explained in its 10/17/25Order, the word “conspiracy” does not appear even once inthe Huffman opinion.Instead of verifying this obvious fact, and admitting hermistake, Attorney Wilson took a different approach. Sheasserts that the Huffman Court:explained that under the intracorporate conspiracydoctrine, “a corporation cannot conspire with its employeesor agents acting within the scope of their employment,” id.at 1060 (citing United States v. Hughes Aircraft Co., 20 F.3d974, 979 (9th Cir. 1994), but that the doctrine “does notapply when the employees have an independent personalstake in achieving the object of the conspiracy,” id. (citingPortman v. County of Santa Clara, 995 F.2d 898, 910 (9thCir. 1993)), and further, “has been held not to bar § 1985claims when the alleged conspiracy involves individualswho are not employees of the same entity.” Id. (emphasisadded).(Doc. No. 31, PageID #3148.) These quotes are fabricated.None of these quotes appear in the Huffman opinion, and,in fact, the Huffman court never once references the HughesAircraft or Portman decisions. It is painfully clear to thisCourt that, despite citing Huffman in three separate briefs,Attorney Wilson has never actually read Huffman. See Parkv. Kim, 91 F.4th 610, 615 (2d Cir. 2024) (“At the very least,the duties imposed by Rule 11 require that attorneys read,and thereby confirm the existence and validity of, the legalauthorities on which they rely”).The misrepresentations do not end there. Attorney Wilsonconcedes that neither Conley v. Gibson, 355 U.S. 41 (1957)nor Doe v. Columbia University, 831 F.3d 46 (2d Cir. 2016)“specifically discuss damages limitations” as she claimed inPlaintiff's Opposition. (Doc No. 31, PageID #3148.) But theCourt finds that her supposed reasoning for nonetheless citingthese cases—that they “reaffirm liberal pleading standardsthat prohibit premature dismissal or narrowing of claimsprior to factual development”—is specious. To start withthe obvious, Conley v. Gibson is not good law. Bailey v.City of Ann Arbor, 860 F.3d 382, 389 (6th Cir. 2017) (“TheSupreme Court overruled the Conley standard in Twombly”).And, with respect to the Columbia University case, AttorneyWilson again fabricated two quotes from that case in hermost recent Response.4 Even without these fabrications, theCourt, when viewing Columbia University in a light mostfavorable to Attorney Wilson, cannot determine how thatcase could support the initial proposition from Plaintiff'sOpposition.Attorney Wilson then claims that Doe v. Claiborne County,103 F.3d 495 (6th Cir. 1996) “clearly h[e]ld that dismissal of§ 1983 claims at the pleading stage was premature, becausefactual development was needed.” (Doc. No. 31, PageID#3148.) Clearly, Attorney Wilson has not read ClaiborneCounty, as the Sixth Circuit in fact affirmed the district court'sdismissal of all of plaintiff's § 1983 claims in that case at the
SAFE CHOICE, LLC, Plaintiff, v. CITY OF CLEVELAND, Defendants., Slip Copy (2025) © 2025 Thomson Reuters. No claim to original U.S. Government Works.3summary judgment stage. See Claiborne County, 103 F.3d at516 (“For the reasons explained, we AFFIRM the dismissalof all section 1983 claims”) (emphasis added).*4 That Court does note that Attorney Wilson did not makeany further misrepresentations concerning the final threecases: (1) Kuhnle Bros., Inc. v. Cnty. of Geauga, 103 F.3d516 (6th Cir. 1997), (2) Jackson v. City of Cleveland, 925F.3d 793 (6th Cir. 2019), and (3) Burgess v. Fischer, 735F.3d 462 (6th Cir. 2013). The Court has considered AttorneyWilson's arguments regarding these three cases, but for thesame reasons stated in the Court's 10/17/25 Order, the Courtfinds that Attorney Wilson violated Rule 11 when she citedthem in Plaintiff's Opposition.Thus, for these reasons, and for the reasons stated in theCourt's 10/17/25 Order, the Court finds that Attorney Wilsonviolated Rule 11 when she cited the above-seven cases inPlaintiff's Opposition.3. Attorney Wilson violated Rule 11 by misrepresentingthe holdings of seven cases in the “final” briefBecause the Court is not persuaded by Attorney Wilson'sarguments regarding the seven misrepresented cases, theCourt is likewise not persuaded by her arguments concerningthe allegedly “final” brief, a copy of which she provided tothe Court at the Contempt Hearing. The same seven casesdiscussed above appeared in the “final” brief, and thus, areseparate Rule 11 violations. Thus, Attorney Wilson againviolated Rule 11 when she submitted the “final” brief.B. The Court will impose sanctions for AttorneyWilson's Rule 11 violations“[T]he purpose of Rule 11 sanctions is to deter rather thanto compensate.” Rentz v. Dynasty Apparel Indus., 556 F.3d389, 400 (6th Cir. 2009) (quoting Fed. R. Civ. P. 11 AdvisoryCommittee Notes (1993 Amendments)). “Therefore, anysanction imposed ‘must be limited to what suffices to deterrepetition of the conduct or comparable conduct by otherssimilarly situated.’ ” Dearborn St. Bdlg. Assocs., LLC v.Huntington Nat'l Bank, 411 F. App'x 847, 852 (6th Cir. 2011)(quoting Rentz, 556 F.3d at 395). Rule 11 permits a districtcourt to issue “nonmonetary directives” and “an order to paya penalty into court.” Fed. R. Civ. P. 11(c)(4).Attorney Wilson suggests that “[d]eterrence has already beenachieved,” that “the lesson has been learned, and [that]the message has been received.” (Doc. No. 31, PageID#3152.) This could not be further from the truth. In additionto the fabricated quotes identified above, Attorney Wilsonfabricated quotes from an additional five cases in her mostrecent Response, four of which are Sixth Circuit cases.5 (SeeDoc. No. 31, PageID #3142, 3145, 3151–52 (citing Rentz v.Dynasty Apparel Indus., 556 F.3d 389, 400 (6th Cir. 2009);Mapother v. Mapother, P.S.C. v. Cooper, 103 F.3d 472, 478(6th Cir. 1996); Century Prods., Inc. v. Sutter, 837 F.2d 247(6th Cir. 1988); Albright v. Upjohn Co., 788 F.2d 1217, 1221(6th Cir. 1986); Eastway Constr. Corp. v. City of New York,762 F.2d 243, 254 (2d Cir. 1985).)Attorney Wilson has not “been scared straight” as shesuggests because she has not even complied with her ownstated objective of “adher[ing] strictly to the highest standardsof accuracy going forward.” (Doc. No. 31, PageID #3153.)Given the fabricated quotes in her Response, the Courtcan only assume that Attorney Wilson is still using AI todraft her briefs and failing—whether through indifference orcarelessness—to verify the accuracy of the AI-drafted quotes.Given that she has not been deterred, the Court finds thatsanctions are appropriate in this case.*5 In considering the appropriate sanction, the Courtconsiders multiple factors. First, the Court finds that AttorneyWilson's conduct is egregious. In sum, Attorney Wilson reliedon four fake cases, mispresented the legal significance ofseven cases twice, and then attempted to mislead the Court inher Response with fabricated quotes from seven cases.6Second, although Attorney Wilson offered a brief andperfunctory apology at the Contempt Hearing, the Courtexpressly finds that her demeanor did not reflect either trueremorse or an understanding of how wrong her conductwas. Indeed, whatever credibility Attorney Wilson's apologyhad was lost by her failing to accept responsibility in herResponse. Instead of conceding her blatant Rule 11 violations,Attorney Wilson responded with new Rule 11 violations.See Jakes v. Youngblood, No. 2:24-cv-1608, Doc. No. 71(W.D. Pa. Oct. 6, 2025) (“the Court believes that sanctionsare necessary to deter Blackburn from future misconduct—especially due to his decision to double-down on his misuseof AI after it was brought to the attention of the Court”).Attorney Wilson also appears to attempt to shift the blameon her law clerk, which is inexcusable. Elizondo v. City ofLaredo, No. 5:25-cv-50, 2025 U.S. Dist. LEXIS 140572, at*6 (S.D. Tex. July 23, 2025) (“While Mr. Piña attributes theerrors to his law clerk's unsupervised AI use, this does notexcuse his failure to verify the cited authorities”).
SAFE CHOICE, LLC, Plaintiff, v. CITY OF CLEVELAND, Defendants., Slip Copy (2025) © 2025 Thomson Reuters. No claim to original U.S. Government Works.4Third, the Court finds that Attorney Wilson's conduct hascaused significant harm “including wasting the opposingparty's time and money, the Court's time and resources, andreputational harms to the legal system.” Morgan v. Cmty.Against Violence, No. 23-cv-353-WPJ/JMR, 2023 U.S. Dist.LEXIS 190181, at *18 (D.N.M. Oct. 23, 2023). By relying onfabricated caselaw, Attorney Wilson has also “cost [her client]an opportunity to make the best possible argument in supportof [its] claim for relief.” Sanders v. United States, 176 Fed.Cl. 163, 169–170 (Ct. Cl. 2025).Fourth, the Court considers that other district courts havetypically imposed monetary sanctions of up to $6,000 forhallucinated citations. See, e.g., Mid Cent. Operating Eng'rsHealth v. Hoosiervac LLC, No. 2:24-cv-00326-JPH-MJD,2025 U.S. Dist. LEXIS 100748, at *3–4 (S.D. Ind. May28, 2025) (ordering $6,000 sanction); Mata v. Avianca, Inc.,678 F. Supp. 3d 443, 446 (S.D.N.Y. 2023) (ordering $5,000sanction). But courts have recently begun to issue higheramounts. See Davis v. Marion Cnty. Superior Ct. Juv. Det.Ctr., No. 1:24-cv-01918-JRS-MJD, 2025 U.S. Dist. LEXIS170047, at *10 (S.D. Ind. Sept. 2, 2025) (recommending$7,500 sanction); Noland v. Land of the Free, L.P., 114 Cal.App. 5th 426, 448 (Cal. Ct. App. 2025) (ordering $10,000sanction). As the Davis court noted, while “[m]onetarysanctions ranging from $2,000 to $6,000 have been imposedin similar contexts in the past few years” there are a“distressing number of cases calling out similar conduct since[those] opinions were issued.” Davis, 2025 U.S. Dist. LEXIS170047 at *9–10; see also Lipe v. Albuquerque Pub. Schs.,No. 23-899 GBW/JMR, 2025 U.S. Dist. LEXIS 185610, at*10 (D.N.M. Sept. 22, 2025) (“The case at bar is by no meansthe first where a party has submitted fabricated case namescaused by the use of an AI tool”).*6 The Court finds that sanctions below $6,000 are notadequate to deter attorneys from haphazardly using AI toolsto craft legal arguments. When imposing sanctions, Rule 11directs a district court to limit sanctions “to what sufficesto deter repetition of the conduct or comparable conduct byothers similarly situated.” Fed. R. Civ. P. 11(c)(4) (emphasisadded); see also Rentz, 556 F.3d at 402 (reversing the districtcourt's imposition of de minimis sanctions because it did not“effectively deter other attorneys from committing similarviolations”). Thus, in imposing sanctions in this case, theCourt also considers how to effectively deter other attorneysfrom committing the same violations here.For all these reasons, and upon careful consideration, theCourt imposes the followingsanctions:1. Within 30 days of this Memorandum Opinion and Order,Attorney Wilson is ordered to pay a $7,500.00 penalty to theClerk of Courts.2. Within 7 days of this Memorandum Opinion and Order,Attorney Wilson shall send a copy of this MemorandumOpinion and Order, the Court's 10/17/25 Order, and herResponse to the Cleveland Metropolitan Bar Association'sCertified Greivance Committee. Within 7 days thereafter,Attorney Wilson shall file proof of service with this Court.3. Within 7 days of this Memorandum Opinion and Order,Attorney Wilson shall send a copy of this MemorandumOpinion and Order, the Court's 10/17/25 Order, and herResponse to Plaintiff Safe Choice, LLC. Within 7 daysthereafter, Attorney Wilson shall file proof of service with thisCourt.4. Within 7 days upon remand of this case to state court,7Attorney Wilson shall file a copy of this MemorandumOpinion and Order, the Court's 10/17/25 Order, and herResponse with the state court. Within 7 days thereafter,Attorney Wilson shall file proof of that filing with this Court.The Court finds that these sanctions are “limited to whatsuffices to deter repetition of the conduct or comparableconduct by others similarly situated.” Fed. R. Civ. P. 11(c)(4). Attorney Wilson is advised that failure to comply withthis Memorandum Opinion and Order may result in furthersanctions.V. ConclusionAs set forth herein, the Court sua sponte issues sanctionsupon Attorney Wilson for her Rule 11 violations. The Clerkis instructed to serve a copy of this Memorandum Opinionand Order, the Court's 10/17/25 Order (Doc. No. 29), andPlaintiff's Response (Doc. No 31) to the following by mail:Cleveland Metropolitan Bar Association Safe Choice, LLCCertified Greivance Committee c/o ANITA SPENCER Attn:Ted Fowles, Bar Counsel 11811 SHAKER BLVD SUITE415 1375 East 9th Street, Floor 2 CLEVELAND OH 44120Cleveland, OH 44114-1785*7 IT IS SO ORDERED.
SAFE CHOICE, LLC, Plaintiff, v. CITY OF CLEVELAND, Defendants., Slip Copy (2025) © 2025 Thomson Reuters. No claim to original U.S. Government Works.5s/Pamela A. BarkerPAMELA A. BARKERDate: October 30, 2025 U. S. DISTRICT JUDGEAll CitationsSlip Copy, 2025 WL 3029553Footnotes1Attorney Wilson initially filed a document on October 24, 2025, which she docketed as “Affidavit/Declaration.” (Doc. No. 30.) Upon the Court's review, Attorney Wilson did not file an affidavit or a declarationand appears to have filed a duplicate copy of her Response, which was filed as a “Brief.” (Doc. No. 30.)Accordingly, the Court considers Doc. No. 31 as the operative Response.2Accord Pittman v. Mich. Corr. Org., SEIU, Local 526, 123 F. App'x 637, 641 (6th Cir. 2005) (“While hecontinues to maintain that these claims are not barred by res judicata, his subjective belief will not preventimposition of Rule 11 sanctions”); Tahfs v. Proctor, 316 F.3d 584, 594 (6th Cir. 2003) (“A good faith beliefin the merits of a case is insufficient to avoid sanctions”); Invst Fin. Group v. Chem-Nuclear Sys., 815 F.2d391, 401 (6th Cir. 1987) (noting that after the 1983 amendments to Rule 11 “[t]he standard by which conductis judged has become more stringent as well; a showing of ‘good faith’ will no longer be sufficient to avoidsanctions”); Nat'l Union Fire Ins. Co. v. Wilkins, No. 1:04-CV-401, 2006 U.S. Dist. LEXIS 19092, at *8 (S.D.Ohio Apr. 13, 2006) (“Also contrary to National Union's arguments, subjective bad faith is not required for acourt to sua sponte issue sanctions”).3See also Oneto v. Watson, No. 22-cv-05206-AMO, 2025 U.S. Dist. LEXIS 201579, at *10 (N.D. Cal. Oct. 10,2025) (finding attorney violated Rule 11 even when the attorney averred in a declaration that “he submittedthe brief with a subjective, good faith belief that the cases cited reflected binding precedent”); Seither, 2025U.S. Dist. LEXIS 143941 at *5–7 (holding citation to non-existent authority violated Rule 11 even when thecourt did “not find that these citations were submitted in bad faith”); Dehghani v. Castro, 782 F. Supp. 3d 1051,1058 (D.N.M. 2025) (rejecting argument that a magistrate judge “did not appropriately weigh [the sanctionedattorney's] good intentions”).4For brevity, the Court does not reproduce those quotes here, but none of the alleged quotes that AttorneyWilson cites in the Response from Columbia University are found in the opinion.5Attorney Wilson relied on three of these cases to fabricate favorable quotes for why the Court should notsanction her. The irony of this is not lost on the Court.6The Court notes that the fabrications in Attorney Wilson's Response are new Rule 11 violations. The Court,however, will not issue a show-cause order regarding these new violations. Attorney Wilson has wastedenough of the Court's time. Those violations are not for today and are better addressed by a different body.See Ohio R. Prof. Cond. 3.1 (“A lawyer shall not bring or defend a proceeding, or assert or controvert anissue in a proceeding, unless there is a basis in law and fact for doing so that is not frivolous, which includesa good faith argument for an extension, modification, or reversal of existing law.”); Ohio R. Prof. Cond. 3.3(a)(1) (“A lawyer shall not knowingly...make a false statement of fact or law to a tribunal or fail to correct a falsestatement of material fact or law previously made to the tribunal by the lawyer”). For the avoidance of doubt,the Court considers Attorney Wilson's new Rule 11 violations for the purpose of demonstrating that she hasnot been deterred and is not sanctioning Attorney Wilson for that conduct.
SAFE CHOICE, LLC, Plaintiff, v. CITY OF CLEVELAND, Defendants., Slip Copy (2025) © 2025 Thomson Reuters. No claim to original U.S. Government Works.67The Court is contemporaneously issuing a separate Memorandum Opinion and Order on the City ofCleveland's Motion for Judgment on the Pleadings. Therein, the Court is dismissing Plaintiff's federal claims,is declining to exercise supplemental jurisdiction over Plaintiff's state law claims and is remanding the caseto state court. The Court retains jurisdiction to enforce the terms of this Memorandum Opinion and Order.See Spradlin v. Richard, 572 F. App'x 420, 428 (6th Cir. 2014) (“A court may award attorney fees, contemptsanctions, and Rule 11 sanctions after the action has been terminated because those issues all require thedetermination of a collateral issue: whether the attorney has abused the judicial process, and if so, whatsanction would be appropriate”) (internal quotation omitted); Red Carpet Studios Div. of Source Advantage,Ltd. v. Sater, 465 F.3d 642, 645 (6th Cir. 2006) (“the Supreme Court has consistently held that federal courtsretain jurisdiction over issues—such as sanctions—that are collateral on the merits”).End of Document© 2025 Thomson Reuters. No claim to original U.S. Government Works.
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