Carol L. Williams v. Tracy Honl
The case
Carol L. Williams v. Tracy Honl, Oregon Court of Appeals, No. A186656, opinion filed April 22, 2026, 348 Or.App. 505. Copy of primary document: `files/sources/D-139-williams-v-honl.pdf`. Source URL: https://www.damiencharlotin.com/documents/2017/Williams_v._Honl_USA_22_April_2026.pdf
What happened
Appellant's attorney Abby Shearer acknowledged that "generative artificial intelligence was used as a research and drafting aid, and quotations and legal propositions were not independently verified against the cited cases before filing." Six of the nine cases cited in the opening brief were cited for nonexistent quotations or propositions not plausibly attributable to them. The court struck the opening brief and noted this was part of a recurrent series of fabricated-law cases before the court.
The rule and the sanction
Sanctions under ORAP 1.40 and ORCP 17. The court awarded respondent $8,044.25 in attorney fees, payable by appellant's attorneys. It permitted an amended opening brief within 28 days, but if filed by the same attorney, the brief must contain a certification that (1) counsel drafted the brief without using generative AI, (2) counsel read each cited source, and (3) every source cited, quoted, or paraphrased exists. The court declined additional court-payable sanctions given the significance of the fee award.
How it could have been avoided
Read every case you cite; cite-checking AI output is not the competent practice of law. Disclose AI-caused errors to the court immediately rather than seeking to quietly amend. Heed the court's certification remedy as a sign that repeat AI misconduct invites escalating restrictions.