Oregon attorney fined $10,000 for AI-generated fake case citations
The Oregon Court of Appeals issued a record $10,000 fine to Salem civil attorney Bill Ghiorso after he submitted a legal brief containing 15 bogus citations and nine fabricated quotes. The appellate court determined Ghiorso signed his name to the filing without verifying the sources, a breach of his professional duties regardless of whether he "knowingly" included false material.
Ghiorso blamed his paralegal's research, which relied on Google search results that included AI-generated summaries. When asked whether fabricated cases were real, Google's AI affirmed they were, Ghiorso said. The court rejected this explanation.
"Counsel at least should have known… that submitting a brief with unchecked and ultimately fabricated citations may breach an attorney's duties of professionalism, truthfulness and candor to the court," Presiding Judge Scott Shorr wrote in the March 18 opinion.
Escalating penalties for AI errors
This is the second financial penalty the Oregon Court of Appeals has issued this year for AI-related errors in legal filings. In December, the court fined another civil attorney $2,000 and established a fee schedule of $500 to $1,000 per artificial error. Under that formula, Ghiorso's fine could have reached $16,500, but the court capped it at $10,000 due to his recent medical troubles.
In February, the court fined self-represented litigant Keith E. Powell $500 for AI errors in an employment board case.
The case background
Ghiorso was hired to challenge the Oregon Liquor and Cannabis Commission's revocation of a marijuana production license in 2022. The licensee, Henry Doiban, had missed a 15-minute window to appear at a remote hearing. Ghiorso said he had only one day to write the AI-assisted memo on a relatively new area of law.
Court records show Ghiorso requested six delays to file his opening brief and ultimately set November 4, 2024 as his self-imposed deadline. The appellate court raised questions about the citations during oral arguments in November 2025.
Missed warning
Patricia Rincon, an assistant Oregon attorney general representing the OLCC, flagged the errors in Ghiorso's brief seven months before the appellate court identified them. Ghiorso did not respond to her email.
In his brief to the appellate court, Ghiorso apologized, saying the errors "fell short of the standards of my office and of the profession."
For legal professionals using AI tools, understanding proper verification procedures is essential. The AI for Legal resource covers responsible AI use in practice. Those managing paralegal teams should review the AI Learning Path for Paralegals to establish clear verification protocols.
Your membership also unlocks:
