# Oregon Court of Appeals fines a lawyer $2,000 for AI-fabricated authority — and sets a per-item price: $500 a fake citation, $1,000 a fake quote

> In Ringo v. Colquhoun Design Studio (345 Or App 301, Dec. 3, 2025), the Oregon Court of Appeals struck an answering brief 'littered with fabricated cases, a fabricated quotation, and fabricated substantive law' and sanctioned respondents' counsel Gabriel A. Watson $2,000 — $500 for each of two non-existent citations and $1,000 for one fabricated statement of law — for what it found 'likely resulted from the use of artificial intelligence.'

- Verification status: verified
- Case type: deployment
- Provider: Unnamed generative-AI legal-drafting tool (no product named in the opinion)
- Client: Court of Appeals of the State of Oregon — Ringo v. Colquhoun Design Studio, LLC, Courts / legal (AI-governance honest-negative) (named)
- Sector: legal services / United States / ops
- Verified on: 2026-08-03
- Canonical URL: https://theinternetninja.com/stories/ringo-v-colquhoun-oregon-appeals-watson-2000-ai-fabricated-citations-500-per-cite-1000-per-quote-2025/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Outcomes

| Metric | Before | After |
| --- | --- | --- |
| $2,000 monetary sanction on respondents' counsel, payable to the Appellate Court Services Division of the Oregon Judicial Department |  |  |
| $500 per fabricated citation + $1,000 per false quotation/statement of law (2 × $500 + 1 × $1,000 = $2,000) — the 'Ringo formula' |  |  |
| Offending brief stricken; any replacement brief requires a certification that counsel did not use generative AI to draft it, read every cited source, and verified each exists |  |  |

## Verification method

Court-adjudicated. Every figure is quoted verbatim from the published Oregon Court of Appeals opinion (345 Or App 301), byte-tied to Wayback via a byte-identical S3 re-host, and corroborated by two independent newsrooms (The Oregonian; ComplexDiscovery).

## Full case file

**Verification status: PENDING — publish-ready, awaiting HUMAN client-confirmation. Not `verified` (no green badge without a recorded client confirmation).**

## The problem
An appeal reached the Oregon Court of Appeals from a Deschutes County dispute
(Charles Ringo v. Colquhoun Design Studio, LLC and Jennifer Cohoon). Respondents'
counsel, Portland attorney Gabriel A. Watson (Watson Law Office PC), filed an
answering brief that the court found was "littered with fabricated cases, a
fabricated quotation, and fabricated substantive law." On its own motion the court
struck the brief and ordered counsel to show cause why it should not impose
sanctions. The court recognized the fabricated law "likely resulted from the use of
artificial intelligence," and expressly rejected the word "hallucination" as
obscuring "the nature and the seriousness of the situation" — calling it "an
exceptionally grave situation."

## What was built
No system was built or deployed here. This is an AI-governance honest-negative: the
story is a court's response to unverified generative-AI output submitted as law. The
opinion (filed Dec. 3, 2025; Chief Judge Erin C. Lagesen writing for a panel with
Presiding Judge Egan and Judge Joyce) names no specific AI product. It identifies
two fabricated case citations and one fabricated statement of law attributed to an
existing case.

## The outcome
The court sanctioned respondents' counsel "$500 for each fabricated citation and
$1,000 for each false quotation or substantive statement of law, for a total of
$2,000," payable to the Appellate Court Services Division of the Oregon Judicial
Department (two fabricated citations × $500 + one fabricated statement of law ×
$1,000 = $2,000). It struck the offending brief and allowed respondents to file a
replacement — but any brief from current counsel must certify that counsel drafted
it without using generative AI, read each cited source, and verified every source
exists. This per-item valuation — $500 a fabricated citation, $1,000 a fabricated
quotation — is the schedule the U.S. District Court for the District of Oregon later
adopted in Couvrette v. Wisnovsky ($15,500), and the opinion itself cites Noland v.
Land of the Free and Garner v. Kadince (both in this corpus) as comparators.

## 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 Watson paid the $2,000,
whether respondents filed a compliant replacement brief within 28 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.