What was hallucinated

Fabricated: Case Law | Opening brief contained at least 15 citations to cases that the court concluded are fabricated (nonexistent) and cannot be located; counsel could not produce sources. || False Quotes: Case Law | At least nine purported quotations attributed to various cases (some to fabricated cases and some to real cases) that do not exist anywhere in Oregon case law. || Misrepresented: Case Law | Multiple instances where actual Oregon cases were cited but the brief inaccurately described the propositions or holdings for which those cases stand.

Details

Petitioner’s opening brief contained at least 15 fabricated case citations and at least nine purported quotations that do not exist in Oregon case law; counsel acknowledged reliance on unverified search-engine results and some use of AI for an outline. Court capped sanctions at $10,000, required a replacement brief limited to accurately described authorities, and required certification that no generative AI was used to draft the brief and that cited authorities were verified.

Sanction teardown · CA Oregon, USA · 2026-03-18

Doiban v. Oregon Liquor and Cannabis Commission

What happened

In CA Oregon, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Opening brief contained at least 15 citations to cases that the court concluded are fabricated (nonexistent) and cannot be located; counsel could not produce sources.
False Quotes (Case Law)

At least nine purported quotations attributed to various cases (some to fabricated cases and some to real cases) that do not exist anywhere in Oregon case law.
Misrepresented (Case Law)

Multiple instances where actual Oregon cases were cited but the brief inaccurately described the propositions or holdings for which those cases stand.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Monetary Sanction (monetary penalty: 10000 USD.)

Additional detail

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://reason.com/volokh/2026/03/20/10k-fine-for-lawyer-who-filed-brief-apparently-containing-many-hallucinations/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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