Stevens v. Paulson does not exist — a fabricated AI citation

In Michael J. Cross v. PHH Mortgage Corporation, et al., the plaintiff cited “Stevens v. Paulson, 254 Or App 111 (2012)” in support of the filing. The U.S. District Court for the District of Oregon found the case does not exist — and, notably, was able to identify exactly what real decision the fabricated citation's volume and page actually belong to: State v. Barajas, 254 Or. App. 106 (2012), a criminal appeal with no relationship to Cross's mortgage dispute.

This is one of the cleaner examples in the sanctions record of a hallucinated citation hijacking a genuine reporter slot. The real Oregon Court of Appeals volume 254 does exist, page 106 does hold a real case, and an AI system generating plausible-looking case law appears to have produced a nearby page number attached to an invented party-name pairing rather than the actual decision that occupies that space in the reporter.

The court's response was an admonishment rather than a monetary sanction — on the lighter end of the sanctions spectrum documented across this database, but still a formal finding that reliance on an unverified, AI-produced citation reached the court's record before anyone caught it. Admonishment-only outcomes like this one are common in the earlier and more isolated entries in this database, distinct from the escalating monetary penalties courts have increasingly imposed as the pattern of AI-hallucinated filings has become harder to treat as a novel, first-time mistake.