# Couvrette v. Wisnovsky (D. Or.): $15,500 Sanction for AI-Fabricated Citations, at $500 per Fake Case and $1,000 per Fabricated Quotation

> A federal magistrate judge in Oregon sanctioned plaintiffs' counsel Stephen Brigandi $15,500 for filing three summary-judgment briefs that cited fifteen non-existent cases and eight fabricated quotations, adopting a $500-per-case / $1,000-per-quotation formula, then struck the briefs, dismissed the case with prejudice, and referred counsel to the Oregon State Bar.

- Verification status: pending
- Case type: deployment
- Provider: Generative-AI legal drafting (product unnamed in the order)
- Client: U.S. District Court for the District of Oregon (Medford Division), Magistrate Judge Mark D. Clarke — Couvrette v. Wisnovsky, No. 1:21-cv-00157-CL, Courts / legal (AI-governance honest-negative) (named)
- Sector: legal-services / US / cross
- Canonical URL: https://theinternetninja.com/stories/couvrette-v-wisnovsky-d-oregon-brigandi-15500-ai-fabricated-citations-500-per-case-1000-per-quote-2025/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Verification method

Signed federal Opinion and Order (ECF No. 215, filed 2025-12-12); Tier-1 court origin byte-tied to Wayback via a byte-identical S3 re-host; two independent newsrooms on the fine (ComplexDiscovery/Rob Robinson states the exact $15,500, archive-bound; The Oregonian rounds it to $15,000), two on the AI-fabrication counts (The Oregonian + Reason/Volokh).

## Full case file

**Verification status: PENDING — checker-graduated at confidence 1.000, awaiting HUMAN client-confirmation. Not `verified`; no green badge until Maneesh confirms.**

This is a court-adjudicated *honest-negative*: a cautionary AI-governance story sourced
from a signed federal court order, not a vendor deployment win.

## The problem
Joanne Couvrette and co-plaintiffs sued her brothers, Mark and Michael Wisnovsky, and
Valley View Winery, Inc. in an intra-family dispute over the winery in Jacksonville,
Oregon. Briefing the cross-motions for summary judgment, Plaintiffs' pro hac vice counsel
Stephen Brigandi filed three briefs that, in the court's words, contained "citations to
fifteen non-existent cases and fabricated quotations falsely attributed to eight legitimate
authorities." The court characterized the conduct as "Plaintiffs' misuse of generative
artificial intelligence." The order names no specific AI product.

## What was built
Nothing was built — this is a misuse case. The court found that the briefs relied on
fabricated authority generated by an unnamed generative-AI tool. Per footnote 8 of the
order, the eight fabricated quotations broke down as "seven fabricated quotations falsely
attributed to real cases and one fabricated quotation falsely attributed to the Restatement
(Second) of Contracts." While the order sanctioned counsel of record, the court also noted
that the client, Ms. Couvrette, "is a serial self-represented litigator who was likely the
person responsible for using artificial intelligence to draft the summary judgment briefs
in this case."

## The outcome
In an Opinion and Order filed December 12, 2025 (No. 1:21-cv-00157-CL), U.S. Magistrate
Judge Mark D. Clarke adopted the Oregon Court of Appeals' valuation of "$500 per
non-existent case and $1,000 per fabricated quotation" and ordered: "Mr. Brigandi is
ordered to pay the Clerk of the Court $15,500 within 30 days of the date of this order."
The figure reconciles as fifteen non-existent cases at $500 ($7,500) plus eight fabricated
quotations at $1,000 ($8,000); the court declined to impose an additional monetary sanction
for the three fabricated quotations that were attributed to the non-existent cases. The
court also ordered the sanctionable briefs "STRICKEN without leave to refile," dismissed
Plaintiffs' claims with prejudice, ordered former local counsel Timothy Murphy to show
cause, and directed the Clerk "to send a copy of this Order to the Oregon State Bar."
A later March 2026 order apportioned the defendants' attorney fees (roughly $80,000 to
Brigandi and $14,205.66 to Murphy, per The Oregonian) — bringing reported total penalties
to about $110,000. Only the $15,500 registry fine and the per-item formula are asserted
here from the Tier-1 order; the attorney-fee totals are from the separate fee order and are
not part of the critical claim.

## Path to green
The $15,500 sanction and the $500/$1,000 formula are stated verbatim in the signed,
published federal order and need no client-confirmation call to be true. What remains for a
human before any badge: confirm from the docket whether Brigandi paid the $15,500 within
30 days, the final apportioned attorney-fee amounts, and whether the sanction or dismissal
was appealed to the Ninth Circuit; and archive-bind The Oregonian secondary (currently
live-only). No war-room agent may set this to `verified`.