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

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,” and it issued a show-cause order asking why the brief should not be stricken and why it should not impose monetary sanctions (source).

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 (source). Counsel represented that his office bars AI for drafting and legal research, that 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 (source). 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” (source).

The outcome

The monetary sanction: $10,000. The court directed petitioner’s counsel to pay $10,000 to the Appellate Court Services Division of the Oregon Judicial Department (source). Per contemporaneous press this is the largest AI-fabrication fine an Oregon court has imposed to date, “a record fine,” reported against the same $10,000 figure by the Salem Reporter and The Oregonian (source).

The Ringo tariff and the $16,500 uncapped minimum. 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,” that is “$500 for each of the 15 fabricated citations and $1,000 for each of the nine fabricated quotations,” then “cap[ped] the sanction at $10,000” (source). 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” (source).

The fabricated authority: 15 citations and nine quotations. The brief carried “at least 15” fabricated case citations and “at least nine” quotations that do not exist anywhere in Oregon case law (source), the same counts an independent report described as “15 bogus citations and nine quotes ‘that had been contrived from thin air’” (source). The court permitted petitioner to file a compliant replacement opening brief within 21 days (source). 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) (source).

How this was verified

This case carries a green badge as a court-adjudicated primary record. The sanction is stated by an independent state appellate court in a signed, published opinion (347 Or App 742, filed March 18, 2026), whose text was re-fetched from the CourtListener PDF on 2026-08-14 and re-checked figure by figure; every quoted figure above appears in that opinion. Two independent newsrooms report the same $10,000 record fine and the 15-citation, nine-quotation counts, so the figures need no client-confirmation call to be true: the Salem Reporter / The Oregonian (Zane Sparling) and Law&Crime. The Salem Reporter article is partly paywalled and is treated as a headline-and-lede corroboration of the $10,000 fine and the fabrication counts.

The honest limit: the opinion itself is fully verifiable, but the post-order docket events (whether Ghiorso paid the $10,000, whether petitioner filed a compliant replacement brief within the 21 days, and any Oregon State Bar or disciplinary follow-on) are docket-gated and were not re-verifiable in this pass, so none of those specifics is asserted here.

Related case files

The $500-a-citation, $1,000-a-quote schedule applied here comes straight from Ringo v. Colquhoun, the earlier Oregon Court of Appeals decision that set the tariff; Doiban is the first case to run that formula into five figures. Noland v. Land of the Free is the California appellate parallel, a first-published opinion with a matching $10,000 sanction for AI-fabricated citations. Kruse v. Karlen reached the same $10,000 level on appeal for an even denser set of fabrications, 22 of 24 citations fake, a useful measure of how far this conduct scales.

Sources

Cited in this case file. Tier 1 = the court’s own signed opinion; Tier 2 = independent press naming the parties. Each figure was checked against the live source on 2026-08-14.

1. Court of Appeals of the State of Oregon, “Doiban v. Oregon Liquor and Cannabis Commission,” 347 Or App 742, filed 2026-03-18 (Shorr, P.J., with Powers and O’Connor, JJ.) (Tier 1, primary appellate opinion; re-fetched from the CourtListener PDF on 2026-08-14). https://storage.courtlistener.com/pdf/2026/03/18/doiban_v._olcc.pdf
2. Salem Reporter / The Oregonian, Zane Sparling, “Salem attorney slapped with record fine after citing case law hallucinated by AI,” 2026-03-25 (Tier 2, independent press; partly paywalled, confirms the $10,000 record fine and the 15-citation, nine-quotation counts). https://www.salemreporter.com/2026/03/25/salem-attorney-slapped-with-record-fine-after-citing-case-law-hallucinated-by-ai/
3. Law&Crime, “Court gives lawyer record fine for AI-caused erroneous brief,” 2026 (Tier 2, independent legal press; corroborates the $10,000 sanction and the AI-fabrication finding). https://lawandcrime.com/high-profile/contrived-from-thin-air-court-slams-attorney-for-submitting-brief-filled-with-made-up-cases-and-quotes-fabricated-by-ai-gets-record-fine/