Doiban v. OLCC
Episode 16
The case
The self-verifying hallucination. Bill Ghiorso's opening brief carried at least 15 fabricated citations and nine fabricated quotations. His explanation was that staff had researched through Google search results and their AI summaries, and that when staff asked Google's AI whether the fabricated cases were real, the AI said they were. The Oregon Court of Appeals applied its standing sanction schedule and imposed the highest Oregon appellate fine for fake cases to that date.
What happened
Ghiorso, a Salem attorney, filed the brief in a marijuana-license revocation appeal in November 2024 and blamed his staff and paralegal when the fabrications surfaced. The research chain had run from Google results to AI-generated summaries, and the only verification step was asking the same kind of system that produced the errors to confirm them.
The rule and the sanction
The court held counsel at least should have known that submitting unchecked, fabricated citations breaches duties of professionalism, truthfulness, and candor. Applying its December 2025 schedule ($500 per fake citation, $1,000 per false quotation or statement of law), the formula came to $16,500; the court capped the fine at $10,000, crediting Ghiorso's detailed explanation, which predated the schedule, and the new verification procedures he reported adopting.
How it could have been avoided
Never ask an AI system to verify AI-generated output; fact-checking a hallucination with another AI prompt compounds the error. Verify in Westlaw, Lexis, or the official reporter. And delegation does not transfer responsibility: the signing attorney owns every citation, including staff-generated research, so staff need training on AI's limits before they research with it.
Watch the episode
This case is covered in Episode 16: Fined $10,000 for 15 Fake Citations and 9 Fake Quotes (watch on YouTube).