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

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.