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AII-1000-62983
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Oregon attorney fined $10,000 for submitting brief with AI-fabricated case citations

An Oregon attorney was fined $10,000 by the Court of Appeals after submitting a brief containing 15 fabricated case citations and nine fake quotes generated by AI. The attorney relied on Google's search engine to verify the cases and blamed a paralegal for the error, but the court found he should have known that submitting unchecked, fabricated citations breaches attorney duties of professionalism and candor.

24 March 2026 Β· Bill Ghiorso Β· Reliability and hallucination
24 March 2026
AII-1000-62983
Quick facts
Category
Reliability and hallucination
Country
United States
Date
24 March 2026
Drafted by
Raidu Incident Detection

What happened

Attorney Bill Ghiorso of Salem submitted a legal brief to the Oregon Court of Appeals containing 15 entirely fabricated case citations and nine fake quotes generated by AI.

According to the judges, Ghiorso's staff asked Google's search engine whether the fabricated cases were real and were told they were authentic. The attorney blamed a paralegal for the AI hallucinations and relied on an AI search engine to verify the data, which he later acknowledged was a fundamental error.

Reported impact

The Oregon Court of Appeals issued a $10,000 fine, the highest fine yet in the state for citing fake cases. Patricia Rinco, an assistant Oregon attorney general, had discovered the fabricated data seven months before oral arguments and flagged the issues to Ghiorso, but he did not respond to that initial warning.

The three-judge panel established that the penalty structure should be $500 for each fake citation and $1,000 for each false quotation or statement of law; Ghiorso's errors initially totaled $16,500 but the judges capped the sanction at $10,000 due to his recent health and medical issues.

Index analysis

The judges wrote that Ghiorso should have known that submitting a brief with unchecked and ultimately fabricated citations may breach an attorney's duties of professionalism, truthfulness, and candor to the court.

Classification

Category
Reliability and hallucination
Industry
Government, security and defence
Country
United States
Harm status
Actual harm
Intent
Unintentional
Timing
Unknown
Harm types
Economic or property, Reputational
Failure modes
Fabricated citation, Hallucination, Overreliance
Consequences
Fine or settlement
AI systems
Google AI search tools

Sources and evidence

Sources not yet published

This record was researched and written by the Index from original reporting. Its sources are still being verified by an editor, and they are listed here once that check is complete. Until then the record carries no reviewer.

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