# Oregon Court of Appeals fines a lawyer $10,000 for AI-fabricated authority — the state's largest such penalty, and the Ringo formula's biggest bill yet

> In Doiban v. OLCC (347 Or App 742, filed Mar. 18, 2026), the Oregon Court of Appeals found that petitioner's counsel William L. Ghiorso signed an opening brief with 'at least 15' fabricated case citations and 'at least nine' quotations that 'do not exist anywhere in Oregon case law.' Applying the Ringo per-item schedule ($500 a fake citation, $1,000 a fake quote) the minimum would have been $16,500; Presiding Judge Scott Shorr capped the sanction at $10,000. The opinion names no dedicated AI product — the fabricated cases came from general search-engine AI summaries staff mistook for real law.

- Verification status: verified
- Case type: deployment
- Provider: Unnamed generative-AI-assisted drafting (no dedicated legal-AI product named; general search-engine AI summaries + an AI-generated outline)
- Client: Court of Appeals of the State of Oregon — Doiban v. Oregon Liquor and Cannabis Commission, Courts / legal (AI-governance honest-negative) (named)
- Sector: legal services / United States / cross
- Verified on: 2026-08-02
- Canonical URL: https://theinternetninja.com/stories/doiban-v-olcc-oregon-appeals-ghiorso-10000-ai-fabricated-15-citations-9-quotes-largest-oregon-fine-2026/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Outcomes

| Metric | Before | After |
| --- | --- | --- |
| $10,000 monetary sanction on petitioner's counsel, payable to the Appellate Court Services Division of the Oregon Judicial Department |  |  |
| Ringo formula ($500 per fabricated citation + $1,000 per fabricated quotation) applied to 15 citations + 9 quotations = a $16,500 uncapped minimum, capped to $10,000 |  |  |
| Cap reasons per the opinion: counsel's show-cause response predated the Ringo decision, counsel gave a detailed explanation, and counsel acknowledged and reportedly implemented new office verification procedures |  |  |

## Verification method

Court-adjudicated. Every figure is quoted verbatim from the published Oregon Court of Appeals opinion (347 Or App 742), byte-tied to Wayback via the byte-identical CourtListener PDF, and corroborated by two independent newsrooms (Law&Crime; ComplexDiscovery).

## Full case file

**Verification status: PENDING — checker-graduated, awaiting HUMAN client-confirmation. Not verified/green.**

## The problem
An appeal reached the Oregon Court of Appeals from a state Liquor and Cannabis
Commission revocation proceeding (OLCC2022MJL1226; Henry Doiban, dba Integrity
Management, petitioner). While the panel prepared for oral argument, it discovered
that petitioner's opening brief "contains fabricated case citations, purported
quotations that do not exist anywhere in Oregon case law … and inaccurate
descriptions of the proposition for which certain cases stand." The court issued a
show-cause order asking why the brief should not be stricken and why it should not
impose monetary sanctions.

## What was built
No system was built or deployed here. This is an AI-governance honest-negative: a
court's response to unverified generative-AI output submitted as law. The opinion
(filed Mar. 18, 2026; Presiding Judge Scott Shorr writing for a panel with Judges
Powers and O'Connor) names **no dedicated AI product**. Counsel represented that his
office bars AI for drafting and legal research — AI was used only to create an
argument outline — and that staff, after limited results in Westlaw and Lexis,
"turned to search engines such as Google and Safari," copying what looked like
"legitimate legal analysis" without verifying it. Counsel noted that even asking
Google whether the fabricated cases are real will "generate a response using its
artificial intelligence search engine, affirming that the fabricated case are in
fact real."

## The outcome
Applying the per-item schedule from Ringo v. Colquhoun ($500 per fabricated
citation, $1,000 per fabricated quotation), the court found "the monetary sanctions
here would be a minimum of $16,500" — "$500 for each of the 15 fabricated citations
and $1,000 for each of the nine fabricated quotations." It then "cap[ped] the
sanction at $10,000," directing counsel to pay that sum to the Appellate Court
Services Division of the Oregon Judicial Department. The cap, per the opinion,
reflected that counsel's show-cause response was due before Ringo issued, that
counsel gave a detailed explanation, and that counsel "acknowledged the need for and
reportedly implemented new office procedures." Per contemporaneous press this is the
largest AI-fabrication fine an Oregon court has imposed to date — the biggest bill
yet under the spreading "Ringo formula." The sanction rests on ORCP 17 C(3) (false
certification) and the attorney's duties of professionalism, truthfulness, and
candor (RPC 3.3, 4.1).

## Path to green
Every figure is established by the published opinion and needs no client call. The
open items are docket-only and asserted by no claim: whether Ghiorso paid the
$10,000, whether petitioner filed a compliant replacement opening brief within 21
days, and any Oregon State Bar or disciplinary follow-on. A green badge — if TIN
carries court-adjudicated honest-negatives — would be a human confirming that docket
posture; the sanction and the quotes are already verifiable from the primary.