Background
Xingkui Guo, a Tennessee college professor, purchased a 1999 Lexus LX 470 online from Meade Motorcars, an Ohio-based car dealer. A dispute arose over the vehicle’s condition, and Guo sued Meade in Tennessee state court. Meade did not appear, and Guo obtained a default judgment of $9,851. Guo then sought to enforce the Tennessee judgment in Sandusky County, Ohio, and the trial court garnished Meade’s bank account for $10,391.28.
Meade moved to vacate, arguing that Tennessee lacked personal jurisdiction because it had no office, employees, or agents in Tennessee and the sale occurred in Ohio. The trial court vacated the foreign judgment. Additionally, Meade sought sanctions after discovering that Guo had submitted filings containing fabricated case citations that appeared to be generated by artificial intelligence. The trial court imposed sanctions, and Guo appealed both rulings.
The Court’s Holding
The Sixth District affirmed both the vacatur and the sanctions. On the jurisdictional question, the court held that Tennessee lacked personal jurisdiction over Meade. The online listing of a vehicle on a national website did not constitute “purposeful availment” of the Tennessee market. The sale was executed through an agreement that required Guo to pay and Meade to ship from Ohio. The fact that Meade offered a FaceTime inspection before shipping did not establish minimum contacts with Tennessee sufficient to satisfy due process.
On the sanctions issue, the court held that Guo had submitted multiple case citations that were fabricated — cases that did not exist in any legal database. The court cited the growing body of Ohio law on AI-hallucinated citations, including Gamble v. Gamble, 2025-Ohio-2381 (12th Dist.) and State v. Coleman, 2026-Ohio-965 (11th Dist.), and held that pro se litigants are held to the same standard as represented parties and have an obligation to verify that their legal authorities are real.
Key Takeaways
- Listing a product for sale on a national website does not constitute purposeful availment of every state where a buyer might be located; personal jurisdiction requires intentional targeting of the forum state.
- Ohio courts will impose sanctions for the submission of AI-hallucinated case citations, and pro se litigants are not exempt from this obligation to verify legal authorities.
- Foreign default judgments enforced in Ohio under the Uniform Enforcement of Foreign Judgments Act remain subject to challenge on jurisdictional grounds.
Why It Matters
This case sits at the intersection of two evolving areas: interstate e-commerce jurisdiction and the legal profession’s reckoning with AI-generated content. The jurisdictional holding provides useful guidance for Ohio businesses that sell products online to out-of-state buyers — a listing on a national platform alone does not consent to jurisdiction in the buyer’s state. The sanctions ruling is part of a growing trend in Ohio (and nationally) of courts penalizing parties who submit AI-generated fabricated citations, reinforcing that the duty to verify legal authorities applies regardless of how the citations were generated or whether the party is represented.