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

The problem

Charles Ringo, a former state lawmaker and retired attorney, sued architectural designer Jennifer Cohoon in 2023, alleging her firm produced faulty plans for a duplex remodel in Bend (source). An arbitrator sided with Cohoon in January and ordered Ringo to pay $1,200 plus $15,000 in fees to her attorney, Portland lawyer Gabriel A. Watson; Ringo appealed, and the case reached the Oregon Court of Appeals (source). This is an AI-governance honest-negative: a court’s response to unverified generative-AI output submitted as law, not a deployment with outcome figures.

What was built

No system was built or deployed here. Watson’s answering brief cited two non-existent cases and used a fabricated quotation attributed to a real case, errors Ringo discovered himself by checking legal databases at the Bend library (source). The Court of Appeals issued an order to show cause why the brief should not be stricken and counsel sanctioned; counsel responded but did not explain how the errors occurred, calling them “inadvertent” (source). The court never received confirmation that AI was used, but Chief Judge Erin C. Lagesen wrote that the fabricated law likely resulted from the use of artificial intelligence, and the opinion names no specific AI product (source).

The outcome

The number that gets quoted: a $2,000 sanction. In a first for Oregon, the Court of Appeals ordered Watson to pay $2,000 to the state judicial department (source).

The per-item price the case is known for: $500 a fake citation, $1,000 a fake quote. The court charged $500 for each of two fabricated citations and $1,000 for the one fabricated quotation or false statement of law (source, source). The court found counsel had violated ORCP 17 C(3), Oregon’s state analogue to Federal Rule 11, by certifying that his legal arguments were “warranted by existing law” when they plainly were not (source).

A “very grave situation,” and a rejection of the word “hallucination.” Lagesen wrote that “although artificial intelligence programs may seem to offer a shortcut for a busy attorney in an individual case, at present, they may create a long cut to justice,” calling it a “very grave situation” (source). The opinion rejected the common term “hallucination”: “We reject that terminology because it obscures both the nature and the seriousness of the situation we face… generative artificial intelligence is not perceiving nonexistent law as the result of a disorder. Rather, it is generating nonexistent law in accordance with its design” (source).

A certification bar going forward. The court struck the offending brief and allowed a replacement, but required any new brief to certify that counsel had read every case cited and verified that every source exists (source). This per-item schedule became the framework a federal court in Oregon adopted days later and the same appellate court applied again in a larger sanction (source).

How this was verified

The origin is a published Oregon Court of Appeals opinion, which is self-authenticating: no client-confirmation call is booked against the court, and green here never depends on the sanctioned attorney confirming anything (source). Checked live on 2026-08-15, the $2,000 sanction, the $500 and $1,000 per-item schedule, the certification requirement and the court’s rejection of “hallucination” were each corroborated by two mutually independent sources naming the parties: The Oregonian’s report and Sugerman Dahab’s pin-cited analysis (source, source). One correction from re-verification: a prior draft of this file quoted the court as calling the conduct an “exceptionally grave situation”; the phrase confirmed on the record and attributed to Chief Judge Lagesen is “very grave situation,” and the file now uses only that (source). The honest limit: the specific AI product is not named in the opinion, and no claim in this file asserts one (source).

Related case files

The Ringo schedule did not stay in state court: the U.S. District Court for the District of Oregon adopted the same per-item math in Couvrette v. Wisnovsky, where it reached $15,500 on a larger set of fabrications. The Oregon Court of Appeals then applied its own Ringo framework again in Doiban v. OLCC, a $10,000 sanction that is the state’s largest to date. For the parallel move in another state, Noland v. Land of the Free is California’s first published appellate opinion sanctioning AI-fabricated citations, the same “first for the state” posture Ringo holds in Oregon.

Sources

Cited in this case file. Tier 1 = the primary court opinion; Tier 2 = independent press and independent legal analysis naming the parties. Figures checked live on 2026-08-15.

1. Court of Appeals of the State of Oregon, “Ringo v. Colquhoun Design Studio, LLC,” No. A186670, 345 Or App 301, 582 P3d 695, 2025-12-03 (Tier 1, primary opinion; Chief Judge Erin C. Lagesen). https://law.justia.com/cases/oregon/court-of-appeals/2025/a186670.html · opinion PDF
2. The Oregonian / OregonLive (Zane Sparling), “‘Very grave situation’: Oregon court slaps attorney with $2,000 fine for AI errors,” 2025-12-04, carried by The Daily Chronicle (Tier 2, independent press naming the parties). https://www.chronline.com/stories/very-grave-situation-oregon-court-slaps-attorney-with-2000-fine-for-ai-errors,392197
3. Sugerman Dahab (Nadia Dahab), “Oregon’s AI Sanctions Framework Is Growing, and So Are the Stakes,” 2026-04-11 (Tier 2, independent appellate-practitioner analysis quoting the opinion with pin cites). https://sugermandahab.com/uncategorized/oregons-ai-sanctions-framework-is-growing-and-so-are-the-stakes/