Couvrette v. Wisnovsky

The timeline

• 2021A family winery dispute reaches the District of Oregon. Attorneys Joseph D. Brigandi and Ryan R. Murphy appear for the plaintiffs.
• 31 Jan 2025A summary-judgment brief cites two cases that do not exist.
• 4 Apr 2025A second brief cites seven more nonexistent cases.
• May 2025A third brief cites six more, plus quotations attributed to real cases, and one to the Restatement (Second) of Contracts, that the sources do not contain. Defendants flag the pattern.
• Mid-2025Counsel's corrective errata misstates the law again, as reported. The court finds persuasive evidence that the plaintiffs themselves drafted the briefs using AI and that counsel filed them without verification, as reported.
• 12 Dec 2025Judge Clarke's sanctions order: $15,500 against Brigandi, payable to the clerk, under Rule 11(b) and Local Rule 83-7; a willful-violation finding against Murphy under Local Rule 83-3.
• 23 Mar 2026Fee apportionment (ECF 225): of the $94,704.38 amended fee award, Brigandi bears 85% and Murphy 15%. The clerk is directed to notify the Oregon State Bar, as reported.

What the AI did

Across three briefs: fifteen nonexistent cases and eight fabricated quotations, seven attributed to real cases, one to the Restatement (Second) of Contracts. As reported, the drafting was the client's, with a generative-AI tool; the filing was the lawyers', without reading the authorities. The opinion places the case within “the quickly expanding universe of cases involving sanctions for the misuse of artificial intelligence,” calling it, as reported, “a notorious outlier in both degree and volume.”

What the court did, and why

Judge Clarke priced the misconduct per unit, a structure unique in this record:

• 15 × $500Nonexistent cases: $7,500 sanction on Brigandi.
• 8 × $1,000Fabricated quotations: $8,000 sanction on Brigandi. Quotations were priced double because a fake quote corrupts a real case's authority.
• $94,704.38Amended attorney-fee award, apportioned in the March 2026 order: Brigandi 85% ($80,498.72), Murphy 15% ($14,205.66).

The totals: $95,998.72 against Brigandi; $14,205.66 against Murphy; $110,204.38 combined. The case was dismissed with prejudice. Some coverage rounds the figure to about $109,700 (the ABA Journal's report); the itemized arithmetic per the docket-cited orders sums to $110,204.38, and we use the exact figure.

What it changed

Couvrette reset the ceiling. Before it, this record's single-matter high was $31,100 (Lacey); after it, “the AI fine” is a six-figure exposure line, with fee-shifting doing most of the damage and the bar referral riding along. It is also the record's clearest client-drafted scenario: a lawyer's name on the caption made the lawyer the owner of fifteen cases he apparently never read.

Sources

• Couvrette v. Wisnovsky, No. 1:21-cv-00157-CL (D. Or.), CourtListener docket; sanctions order reported at 2025 WL 4109655; fee apportionment at ECF 225
• Legal AI Governance tracker entry (with WL and ECF citations)
• Q1 2026 sanctions survey (David S. Kemp), amounts and procedural detail as reported

Related

• The full sanctions record
• Wadsworth v. Walmart, the same exposure from a firm's own tool
• Whiting v. City of Athens, the appellate version of the stacked remedy
• Every verified AI standing order

Checked 4 August 2026. Figures confirmed against the docket (12 Dec 2025 order; ECF 225); narrative detail marked as reported rests on the linked coverage. Information, not legal advice.