AI Risk Wire

Cases › made things up › LR-2026-0465

Attorney fined for citing AI-generated cases

Preliminary Why: 1 report: Gizmodo · subject to change · 1 independent report

Status: action reported, no fix

Severity minor
Loss or records US$10,000
Reported 26 Mar 2026

No source states: developer and model, agent tool, could do, deployer, industry.

Severity minor: test: contained to one deployer (one attorney, one brief); the sources state no third party touched

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.

What happened

1 · What went wrongThe attorney submitted a brief to the Oregon Court of Appeals containing 15 fake citations and nine fake quotes.

What was done

The fine was capped at $10,000 although the per-item total was $16,500.

Risks

Made-up output relied on
Primary36 incidents

Sorted by rule from the case's fields; not yet read from the sources.

Controls

Not yet read for controls. Controls that mitigate the primary risk:

Application

Grounding and fact checks · Human approval for high-impact actions · Output filtering and redaction · People told they are dealing with AI

Evidence

No source states: what the AI was doing, what it reached or did, how it was caught, when it happened, when it was found, how many records were exposed, a count of the other parties affected, any court case, the cause, what set it off.

Show the full account: 3 items from the primary sources

What happened, in order

  1. 2025-12 Oregon appeals court first fined a different attorney for citing fake AI cases.

Not dated in the sources:

  • Oregon court fined the attorney $10,000 for the brief with AI-hallucinated citations.
  • Attorney reportedly blamed a paralegal and initially challenged the fine.
Show every field, with its source and grade

What happened

Earliest source we hold
2026-03-26
D inferred by us from the described behaviour, reason shown
What went wrong
made things up
C one secondary source states it

Impact

Direct loss
$10,000
C one secondary source states it
Severity
minor
D inferred by us from the described behaviour, reason shown
Why this severity
test: contained to one deployer (one attorney, one brief); the sources state no third party touched
D inferred by us from the described behaviour, reason shown

Context

Country
United States
C one secondary source states it

Notes on gaps

The Dec 2025 fine of another attorney is a timeline precedent only and was not treated as part of this incident.

LR-2026-0465 · version 1 · published 2026-11-01 after automatic checks; not yet checked field by field by a person · JSON