“submitting a brief with unchecked and ultimately fabricated citations may breach an attorney’s duties of professionalism, truthfulness, and candor to the court.”
The file →
- Doiban v. Oregon Liquor and Cannabis Commission involving petitioner's counsel
- Counsel submitted an opening brief containing 15 fabricated case citations and 9 non-existent quotes from unverified AI/search output
- Court imposed a $10,000 monetary sanction and ordered a replacement brief with certified non-AI verification
- Oregon Court of Appeals
- Decided March 18, 2026; counsel admitted using unverified search results and AI for outlining