Holding / Framework
Court dismissed plaintiff's claims, imposed approximately $110,000 in monetary sanctions and fee-shifting, and referred the matter to the Oregon State Bar after finding attorneys repeatedly submitted briefs containing AI-fabricated authorities. Local counsel held jointly accountable for AI-fabricated content in co-signed filings, even where lead counsel drafted the briefs.
Triggering Conduct
Across three separate briefs on cross-motions for summary judgment over a five-month period (January-May 2025), plaintiff's briefing included 15 AI-generated fake case citations and eight fabricated quotations. Pattern escalated: Jan 2025 = 2 fake citations; April 2025 = 7 fictitious citations; May 2025 = 16 invented references. Local counsel was sanctioned alongside lead counsel for failure to vet filings he co-signed.
Sanctions / Disposition
Approximately $110,000 total: $80,000 in opposing-side attorney fees plus $15,000 in fines against lead attorney Stephen Brigandi (San Diego, pro hac vice for plaintiff); approximately $14,000 in sanctions against local counsel Timothy Murphy (Oregon). Plaintiff's claims dismissed. Matter referred to Oregon State Bar.
Primary Source
https://www.abajournal.com/news/article/oregon-federal-judge-hands-down-110000-penalty-for-ai-errors · secondary_aggregator (ABA Journal); primary docket pull pending
Tags
9th_circuit, hallucinated_citations, dismissal, attorney, civil, large_sanction, local_counsel_liability, escalation_pattern, bar_referral