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

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.