The Court of Appeals of Oregon has ordered $10,000 in sanctions against an attorney whose reliance on AI tools produced a brief riddled with incorrect citations.
In the case of Doiban v. Oregon Liquor and Cannabis Commission, the court found that nine of 27 legal citations in a ten-page brief were incorrect due to the use of and reliance upon AI tools.
The ruling, issued in March 2026, represents a significant escalation in judicial responses to AI-generated errors in legal filings submitted to appellate courts.
Courts across the United States imposed at least $145,000 in sanctions for AI-generated fake citations during the first quarter of 2026 alone, according to tracking data compiled by researchers monitoring judicial responses to generative AI failures.
Oregon is believed to account for $109,700 in combined sanctions and adverse costs, representing the largest aggregate penalty tied to a single attorney’s AI-related misconduct.
A separate $30,000 fine was issued by the U.S. Court of Appeals for the Sixth Circuit, reported as the steepest sanction linked to fabricated citations at the federal appellate level.
The Oregon case stands as a warning to legal practitioners who adopt AI drafting tools without independently verifying every citation produced by those systems.
The Doiban ruling makes clear that appellate courts are prepared to impose substantially harsher consequences than trial courts, where fines have typically stayed below $10,000.
Legal professionals across the country have faced growing scrutiny over their use of generative AI tools, following a string of high-profile cases involving invented case names, false quotations, and non-existent rulings.
Bar associations and courts have responded by introducing new guidance requiring attorneys to certify the accuracy of AI-assisted work before filing documents in any court proceeding.
The cumulative sanctions picture emerging from the first quarter of 2026 suggests courts are moving decisively to deter casual or unverified AI use in formal legal submissions.
For firms and solo practitioners alike, the cost of failing to verify AI-generated research is now measurable not just in fines but in reputational damage before the courts that matter most.