{"schema_version":"0.10.0","id":"LR-2026-0465","record_version":1,"title":"Attorney fined for citing AI-generated cases","verification":{"human_verified":false,"method":"automated_gate","auto_verified":true,"score":45.5,"score_breakdown":{"source_authority":12.1,"independent_corroboration":7.0,"implicated_party_confirmed":0.0,"citation_integrity":14.0,"specificity":3.0,"completeness":2.56,"unhedged_language":4.58},"checks":{"schema_valid":true,"every_field_cited":true,"quotes_verbatim":true,"source_fetched":true,"distinct_incident":true,"dates_plausible":true,"sources_agree":true,"source_describes_incident":true,"severe_backed_by_source":true,"record_integrity":true,"eligible":true,"about_this_case":true},"gate_version":"gate-2026-10-18.7","cross_check_model":null,"cross_check_agreement":null,"duplicate_of":null,"verified_by":null,"verified_at":"2026-11-01","extraction_run_id":null,"evidence_level":{"level":"preliminary","reason":"1 report: Gizmodo · subject to change","original_document":null,"reports_total":1,"reports_independent":1,"reports_derivative":0,"developing":false,"disputed":false,"rules_version":"evidence-2026-10-29.1","computed_at":"2026-11-01","history":[{"date":"2026-11-01","from_level":null,"to_level":"preliminary","reason":"1 report: Gizmodo · subject to change"}]},"sources_hash":"64c54c606e839a1e228a4a6ee0ac1c845d8b118e3d3fb098824b0afa3347dc6e"},"system":{"model_name":null,"model_version":null,"developer":"unknown","harness":null,"tools_granted":[],"permissions_scope":null,"autonomy_level":"unknown","guardrails_present":[],"deployment_context":"unknown","tier":null,"lifecycle_stage":null,"integration_type":null,"intended_use":null,"safeguard_state":null,"production_intended":null},"event":{"date_occurred":null,"date_disclosed":"2026-03-26","incident_class":"hallucination","failure_class":null,"agent_involved":null,"secondary_failure_classes":[],"trigger":"unknown","duration":null,"detection_method":"unknown","summary":"An attorney in Oregon, Bill Ghiorso of Salem, submitted a legal brief to the Oregon Court of Appeals that contained fifteen fake citations and nine fake quotes produced by AI. The court fined him $10,000, below the $16,500 that adding up the hallucinations would have produced. He reportedly blamed a paralegal and initially challenged the fine. According to the judges, his staff had asked Google whether the cases were real and were told they were authentic. The judges wrote that submitting unchecked citations may breach duties of candor to the court. It is unclear whether the hallucinations came from Google's AI or from other chatbots.","tags":[],"date_detected":null,"near_miss":null,"root_cause":null,"root_cause_detail":null,"failure_class_detail":null,"responsible_party":null,"adversarial_actor":null,"input_provenance":null,"time_to_contain":null,"operations_paused":null,"remediation":null,"precursor_events":null},"impact":{"direct_loss_usd":10000.0,"remediation_hours":null,"records_exposed":null,"third_parties_affected_count":null,"severity":"minor","severity_because":"minor test: contained to one deployer (one attorney, one brief); the sources state no third party touched","harm_class":[],"affected_description":null,"protected_class_involved":null,"data_categories_exposed":[],"loss_range_usd":null,"reversibility":null,"downstream_exposure_count":null},"evidence":{"sources":[{"url":"https://gizmodo.com/attorney-hit-with-historic-fine-for-citing-ai-generated-cases-2000738651","publisher":"Gizmodo","date":"2026-03-26","type":"press","title":"Attorney Hit With Historic Fine for Citing AI-Generated Cases - Gizmodo","archived_url":null,"attachment":"first_report","independence":"independent"}],"per_field_confidence":{"impact.direct_loss_usd":"C","context.country":"C","event.incident_class":"C","impact.severity_because":"D","impact.severity":"D","event.summary":"C","system.autonomy_level":"D","system.deployment_context":"D","event.trigger":"D","event.detection_method":"D","system.developer":"D","event.date_disclosed":"D","context.denominator_available":"D"},"field_citations":{"impact.direct_loss_usd":[{"source_index":0,"quote":"A court in Oregon has issued a fine of $10,000 to an attorney who submitted a legal brief with citations and quotes hallucinated by AI, according to a new report from the Oregonian."}],"context.country":[{"source_index":0,"quote":"A court in Oregon has issued a fine of $10,000 to an attorney who submitted a legal brief with citations and quotes hallucinated by AI, according to a new report from the Oregonian."}],"event.incident_class":[{"source_index":0,"quote":"The attorney, identified by the Oregonian as Bill Ghiorso in Salem, submitted a legal brief to the Oregon Court of Appeals that contained 15 fake citations and nine fake quotes."}],"impact.severity_because":[{"source_index":0,"quote":"The attorney, identified by the Oregonian as Bill Ghiorso in Salem, submitted a legal brief to the Oregon Court of Appeals that contained 15 fake citations and nine fake quotes."}],"impact.severity":[{"source_index":0,"quote":"The attorney, identified by the Oregonian as Bill Ghiorso in Salem, submitted a legal brief to the Oregon Court of Appeals that contained 15 fake citations and nine fake quotes."}],"event.summary":[{"source_index":0,"quote":"A court in Oregon has issued a fine of $10,000 to an attorney who submitted a legal brief with citations and quotes hallucinated by AI, according to a new report from the Oregonian."},{"source_index":0,"quote":"The attorney, identified by the Oregonian as Bill Ghiorso in Salem, submitted a legal brief to the Oregon Court of Appeals that contained 15 fake citations and nine fake quotes."},{"source_index":0,"quote":"Adding up all the hallucinations, Ghiorso was first hit with a $16,500, but the judges capped that at $10,000."},{"source_index":0,"quote":"Ghiorso reportedly blamed a paralegal for the AI hallucinations and initially challenged the fine."},{"source_index":0,"quote":"According to the judges in the case, Ghiorso explained his staff had asked Google if the cases cited were real and were told that they were authentic:"},{"source_index":0,"quote":"The judges wrote that Ghiorso should have known “submitting a brief with unchecked and ultimately fabricated citations may breach an attorney’s duties of professionalism, truthfulness, and candor to the court.”"},{"source_index":0,"quote":"It’s unclear if Ghiorso’s office used Google’s AI responses in the search engine exclusively or if other AI chatbots were utilized to create the hallucinations."}]},"notes_on_gaps":"Single press source (Gizmodo, citing the Oregonian). Not stated: date the incident occurred, date detected, detection method, which AI tool produced the fake citations (the source says it is unclear whether Google's AI or other chatbots were used), the model, developer or version of that tool, any autonomous agent, trigger, root cause, and any remediation by the attorney. The disclosure date is in the article header only, not in the text, so it is omitted. Judgements made: no failure_class or agent_involved because no autonomous agent is described; the $10,000 fine is recorded as direct_loss_usd although it is a sanction rather than a loss; severity set to minor because the sources name one attorney and one brief and state no third party touched; country US is inferred from the Oregon court; responsible_party set to deployer because the attorney submitted the brief; the Google staff check is recorded as failed grounding control I7. The Dec 2025 fine of another attorney is a timeline precedent only and was not treated as part of this incident. The fine amount is stated as $10,000 in the source; the $16,500 figure is the per-item total the judges capped. [case created by the backfill: read by claude-haiku-5-5, backfill-2026-11-01.2, 2026-11-01; not yet reviewed] [2026-11-01: evidence level set: Preliminary (1 report: Gizmodo · subject to change)]"},"context":{"industry":null,"org_size_band":null,"country":"US","denominator_available":false,"denominator":null,"related_incident_ids":[],"systemic_exposure":null,"shared_model_id":null,"upstream_incident_id":null,"incident_evidence":null,"regulatory":null,"coverage":null},"narrative":{"steps":[{"step":"went_wrong","text":"The attorney submitted a brief to the Oregon Court of Appeals containing 15 fake citations and nine fake quotes.","quote":"The attorney, identified by the Oregonian as Bill Ghiorso in Salem, submitted a legal brief to the Oregon Court of Appeals that contained 15 fake citations and nine fake quotes.","source_index":0,"grade":"C"},{"step":"done","text":"The fine was capped at $10,000 although the per-item total was $16,500.","quote":"Adding up all the hallucinations, Ghiorso was first hit with a $16,500, but the judges capped that at $10,000.","source_index":0,"grade":"C"}],"model":"claude-haiku-5-5","prompt_version":"backfill-2026-11-01.2","extracted_at":"2026-11-01","source_urls":["https://gizmodo.com/attorney-hit-with-historic-fine-for-citing-ai-generated-cases-2000738651"]},"analysis":{"sections":{"timeline":[{"text":"Oregon appeals court first fined a different attorney for citing fake AI cases.","quote":"The appeals court in Oregon first fined a different attorney for the practice back in December 2025.","source_index":0,"when":"2025-12"},{"text":"Oregon court fined the attorney $10,000 for the brief with AI-hallucinated citations.","quote":"A court in Oregon has issued a fine of $10,000 to an attorney who submitted a legal brief with citations and quotes hallucinated by AI, according to a new report from the Oregonian.","source_index":0,"when":null},{"text":"Attorney reportedly blamed a paralegal and initially challenged the fine.","quote":"Ghiorso reportedly blamed a paralegal for the AI hallucinations and initially challenged the fine.","source_index":0,"when":null}]},"model":"claude-haiku-5-5","prompt_version":"backfill-2026-11-01.2","extracted_at":"2026-11-01","source_urls":["https://gizmodo.com/attorney-hit-with-historic-fine-for-citing-ai-generated-cases-2000738651"]}}