A court in Oregon has issued a fine of $10,000 to an attorney who submitted a legal brief with citations and quotes hallucinated by AI, according to a new report from the Oregonian. It’s the highest fine yet for citing fake cases in the state and would have been higher, but the judges offered some leniency, according to the newspaper.
The attorney, identified by the Oregonian as Bill Ghiorso in Salem, submitted a legal brief to the Oregon Court of Appeals that contained 15 fake citations and nine fake quotes. Ghiorso reportedly blamed a paralegal for the AI hallucinations and initially challenged the fine.
The appeals court in Oregon first fined a different attorney for the practice back in December 2025. The three-judge panel established that this kind of issue should be met with $500 for each fake citation and $1,000 for each false quotation or statement of law. Adding up all the hallucinations, Ghiorso was first hit with a $16,500, but the judges capped that at $10,000.
According to the judges in the case, Ghiorso explained his staff had asked Google if the cases cited were real and were told that they were authentic: “If one asks Google’s search engine whether many of the fabricated cases are real, it will generate a response using its artificial intelligence search engine, affirming that the fabricated [cases] are in fact real.”
People frequently think they can fact-check something created with AI by asking the AI chatbot whether it’s real. Generative artificial intelligence tools are not reliable fact-checkers. Some people also think they can ensure their AI chatbot doesn’t make up fake information if they simply prompt the tool with an instruction like “don’t hallucinate.” This doesn’t work.
The judges wrote that Ghiorso should have known “submitting a brief with unchecked and ultimately fabricated citations may breach an attorney’s duties of professionalism, truthfulness, and candor to the court.”
It’s unclear if Ghiorso’s office used Google’s AI responses in the search engine exclusively or if other AI chatbots were utilized to create the hallucinations. Ghiorso didn’t immediately respond to questions emailed on Thursday.
There have been countless stories in recent years of attorneys submitting legal documents with AI hallucinations. Most attorneys get off with a warning, but there are some judges who will issue monetary sanctions like the fine issued to Ghiorso.
Another attorney in Oregon was reportedly fined $500 last month for one fake citation. A three-judge panel in New Orleans ordered an attorney to pay $2,500 for citing fake cases last month.
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