Oregon: a per-infraction rate for AI hallucinations

What happened

• The filingPortland civil attorney Gabriel A. Watson filed briefs citing two made-up cases and using a fabricated quotation attributed to a real case.
• The sanction$2,000, broken out as $500 per fabricated citation and $1,000 for the fabricated quotation.
• The courtOregon Court of Appeals, Chief Judge Erin Lagesen writing, December 2025.

“Although artificial intelligence programs may seem to offer a shortcut for a busy attorney in an individual case, at present, they may create a long cut to justice.”

The court called it a “very grave situation”.

Why the pricing is the story

Notice that the fabricated quotation costs twice the fabricated citation. That is a considered judgment, and it matches what the courts have been saying independently. A fake case name is caught by a citation checker in seconds. A fake quotation attributed to a real case is caught only by someone who opened the case and read it, which is exactly the failure the Sixth Circuit identified in United States v. Farris, where every case cited was real and the quotations were not.

Oregon has priced the harder failure higher. That is the first time any court has expressed the difference in money.

What it changes

It converts a discretionary risk into a multiplication. Set it against the rest of the record and the effect is immediate: the twenty-plus fabrications in Whiting, or the sixteen fabricated quotations in Fletcher, become a calculable number rather than a judgment call.

That is the form insurers and general counsel can actually use. A discretionary sanction cannot be underwritten. A published rate can.

Sources

• Ringo v. Colquhoun Design Studio, LLC, Oregon Court of Appeals, December 2025. The opinion was not opened from this session.
• Recorded from contemporaneous reporting, including The Daily Chronicle and Washington State Bar Association commentary. Figures and the quoted language are consistently reported; we carry no citation to a page of the opinion because we have not read it.

Related

• The full sanctions record
• United States v. Farris, where the quotations were the failure
• Couvrette v. Wisnovsky, the largest US penalty
• For insurers

Checked 5 August 2026. The opinion was not read at source, and this page carries no quotation from the document itself. Treat the detail as reported until the opinion is pulled.

Common questions

How much does a fake citation cost in Oregon?

In December 2025 the Oregon Court of Appeals sanctioned a Portland attorney $2,000, calculated as $500 for each of two fabricated citations and $1,000 for one fabricated quotation. It is the first published per-infraction rate for AI hallucinations by any court.

Why does a per-infraction rate matter?

Because it makes the exposure calculable in advance. Every other sanction on this record is discretionary, so a firm cannot price the risk until after a judge has decided. A published rate turns it into a number a managing partner or an insurer can multiply, and a brief with twenty fabricated citations becomes a five-figure event before anyone argues about intent.

What did the Oregon court say about AI?

Chief Judge Erin Lagesen described it as a 'very grave situation' and wrote that although artificial intelligence programs may seem to offer a shortcut for a busy attorney in an individual case, at present they may create a long cut to justice.

Has the Oregon rate been used by other courts?

It has been reported as adopted by federal courts in the same jurisdiction, and a federal court in Oregon has since surveyed the available sanctions for AI fake citations at length. We have not read those orders and do not describe them further here.