Holding / Framework
Oregon Court of Appeals characterized the proliferation of AI-generated sketchy legal documents as 'a very grave situation' and established a per-infraction sanctions framework: $500 per fabricated citation, $1,000 per fabricated quotation. The framework has been cited in subsequent federal sanctions orders adopting analogous per-infraction calculation.
Triggering Conduct
Portland attorney Gabriel A. Watson filed brief citing two nonexistent cases and one fabricated quotation. Watson initially attempted to attribute the error to his assistant having mistakenly filed a 'draft/placeholder' brief; later acknowledged and apologized for the AI-generated errors. Court rejected the explanation as not constituting a 'clear explanation' of how the errors occurred.
Sanctions / Disposition
$2,000 total. Court established a per-infraction rate framework: $500 per fabricated citation × 2 citations = $1,000; plus $1,000 per fabricated quotation × 1 quotation = $1,000.
Primary Source
https://www.chronline.com/stories/very-grave-situation-oregon-court-slaps-attorney-with-2000-fine-for-ai-errors,392197 · secondary_aggregator (Daily Chronicle / NW Sidebar); primary opinion pull pending
Tags
state_court, oregon, hallucinated_citations, per_infraction_rate, framework_setter, attorney