Was Morgan v. Jones sanctioned over AI-generated citations?

Morgan v. Jones (Ohio CA (1st), June 26, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: AI-citation sanction denied as a matter of warning; vexatious-litigator motion also denied.. No monetary penalty in this order.

Which AI tool was involved in Morgan v. Jones?

The order in Morgan v. Jones does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

June 26, 2026 · AI sanctions database

Morgan v. Jones

Morgan v. Jones is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: Ohio CA (1st)
Date: June 26, 2026
Party: Pro Se Litigant
AI tool: Not identified in the order
Outcome: AI-citation sanction denied as a matter of warning; vexatious-litigator motion also denied.
Penalty: No monetary penalty in this order.

Warning

What the record shows

The First District Court of Appeals of Ohio addressed a self-represented appellant whose brief cited two cases the court could not locate in any reporter, including one carrying an unusual three-party caption that corresponded to no real decision. The court stated the citations bore the hallmarks of AI hallucinations, while noting the appellant neither confirmed nor denied using generative artificial intelligence. Because the court's local rule governing AI use (Loc.R. 45) was not in effect when the brief was filed, the court declined to impose sanctions and denied the opposing party's sanctions motion as a matter of warning. The court separately denied a motion to declare the appellant a vexatious litigator.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗ · CourtListener record ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · Ohio CA (1st)

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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