Attorney Fined Heavily for AI-Generated Legal Brief with Fake Cases

An attorney in Oregon has been hit with a hefty penalty by the state’s Court of Appeals for submitting a legal brief riddled with “nonexistent caselaw” generated by artificial intelligence.

Bill Ghiorso has been ordered to pay a $10,000 fine to the Oregon Judicial Department’s Appellate Court Services Division. This penalty stems from his submission of an “unchecked and ultimately fabricated” document, which he acknowledged did not meet the professional standards expected of his practice. The brief, according to the court’s order, contained “at least 15” fictional citations and “at least nine purported” quotes that were entirely made up.

“My law clerk was using a search engine that we’ve now completely discarded,” Ghiorso told three appeals court judges in video shared by Portland NBC affiliate KGW. The judges, however, did not appear to be convinced by his explanation.

“It couldn’t just be a search engine; something produced and wrote the brief that your name is on,” remarked presiding judge Scott Shorr during the proceedings.

The brief was filed in the case of Doiban v. OLCC after the Oregon Liquor and Cannabis Commission (OLCC) revoked a marijuana production license from Henry Doiban, who failed to attend a remote hearing due to a missed 15-minute window, as reported by The Oregonian.

Doiban attributed his absence to technological issues and enlisted Ghiorso to contest the commission’s decision. Filed in November 2024, Ghiorso’s brief was submitted during a period when he was dealing with significant health problems and had already used up all possible extensions. Consequently, he delegated the task to his staff, who relied on search engines like Google and Safari, mistakenly believing they were conducting legitimate legal research.

According to the appeals court, the fabricated citations were brought to Ghiorso’s attention by attorneys for the OLCC in April 2025 before they filed their response. He reportedly did not respond.

Ghiorso then “did not address the nonexistent citations and quotations in any manner for seven months until in-person questioning by the court,” the the Oregon Court of Appeals stated, “despite having been made aware of them.”

In November 2025, the Oregon Court of Appeals ordered Ghiorso to defend his brief and show why it shouldn’t be thrown out, and why the court should not “impose monetary sanctions for submitting a brief to this court that contains nonexistent caselaw and nonexistent quotations.”

The appeals court adds that “when given the opportunity to explain, counsel did not provide any explanation for the lack of correction during that lengthy time period.”

The judges suggested that this illustrated Ghiorso “minimized the gravity of the situation.”

“Whether an attorney relies on a partner or associate for an initial draft of a brief or, instead, overly relies on a computer, which may be risky but perhaps not improper on its own, prior to filing, the attorney signing the final filed brief is certifying that the citations therein are accurate and not contrived from thin air,” the order states.

In considering whether — and then how much — to sanction the attorney, the judges considered recent examples. In December 2025, in a different case, the appeals court concluded that “‘monetary sanctions, payable by [the] respondents’ counsel, in the amount of $500 for each false citation, and $1,000 for each false quotation or statement of law’ were appropriate.”

Such penalties would have added up to a minimum of $16,500 for Ghiorso, but the judges decided to “cap the sanctions” at $10,000, which is still a record fine for this sort of error, per KGW. They say they did so in part because Ghiorso “has acknowledged the need for and reportedly implemented new office procedures to prevent another occurrence in the future.”

The appeals court also said it will allow the attorney to file a proposed replacement brief, making edits as necessary but without raising any new arguments.