Sandusky Lawyer Faces Sanctions Hearing for Alleged AI-Hallucinated Citations

Another one for the counter. On May 12, 2026, Erie County (Ohio) Court of Common Pleas Judge Tygh Tone struck five motions filed by Sandusky attorney D. Jeffery Rengel and ordered him to appear on June 16 to show cause why sanctions should not be entered against him. Opposing counsel said the cases he cited do not exist — and bear the "hallmark indicators" of generative AI hallucination.

What plaintiffs alleged

Lefevre's motion accused Rengel of using generative AI in documents filed with the court and asked Judge Tone to strike previously filed motions containing inaccuracies. Two examples were laid out in the public record:

• "Toledo v. State." Plaintiffs' counsel could not find the cited case. A search of the journal pulled up two unrelated decisions — one civil, one criminal — neither with that caption.
• "Staymate, Inc. v. Staymate, LLC." No case with that caption exists. The cited location returned "a juvenile appeal wholly unrelated to anything at issue in this case." "It appears that case was also hallucinated by (generative AI)," the motion states.

The plaintiffs grounded their AI allegation in what they called "hallmark indicators": inconsistent citation format, cases cited incorrectly, incorrect quotation attributions, and inconsistent arguments — the same fingerprint pattern courts have now seen in dozens of post-Mata orders.

The April 9 letter

Lefevre sent Rengel a formal letter on April 9 — entered as a court exhibit — demanding that the offending motion be withdrawn, that Rengel review and pull any other AI-generated filings that had not been independently verified, and that he disclose the reason for any such withdrawals. The letter cited Ohio's Rules of Professional Conduct.

Rengel responded the next day acknowledging he could not locate the Staymate case and filed an amended motion to dissolve a TRO. In an email included in the court record, he wrote: "Not quite sure how that happened."

The opposition — and the order

Rengel opposed sanctions, arguing the plaintiffs were "merely inferring" AI use from "formatting irregularities and alleged citation mistakes." He did not confirm or deny in his opposition whether AI was used, and contended that imperfect citations did not warrant striking the filings or rise to sanctionable conduct — at most, he wrote, opposing counsel disagreed with some citations and believed certain statements were "imperfectly supported."

Judge Tone disagreed. On May 12, he signed an order striking five of Rengel's motions and directing him to appear on June 16 to "show cause why sanctions should not be entered against him."

Why this one matters

This is not a federal multidistrict case or a six-figure penalty. It is a county common pleas docket in Erie County, Ohio. That is exactly the point. The AI-hallucination problem has now completely descended from the SDNY headlines of Mata v. Avianca into the day-to-day civil dockets where most American litigation actually lives.

A few practitioner takeaways:

• Silence is not a defense. Refusing to confirm or deny whether AI was used does not make the citations exist. Courts now read non-denial as a tell.
• "Not quite sure how that happened" is the new Mata. Rule 11 and the parallel state rules require an attorney to know how a citation got into a brief signed under their name.
• Verification is non-negotiable. Every cite, every quote, every pin — pulled independently before filing. This is the COUNSEL Framework's "Scrutiny" pillar in one sentence.
• Opposing counsel are the new enforcement layer. Lefevre's April 9 letter, then motion, then exhibit packet — that is the playbook now. Expect to receive one. Expect to send one.

The June 16 hearing will determine the penalty. We have added the case to LegalTek's live AI sanctions database and will update the entry once the show-cause order is decided.