Background: The Oregon Supreme Court building in Salem, Oregon, home to the Oregon Court of Appeals (Google Maps). Inset: Bill Ghiorso (Oregon Judicial Department/KGW/YouTube).
The Oregon Court of Appeals has hammered an attorney with a record fine for submitting a legal brief filled with “nonexistent caselaw” fabricated by artificial intelligence.
Bill Ghiorso must pay $10,000 to the Oregon Judicial Department”s Appellate Court Services Division for his “unchecked and ultimately fabricated” filing that he admitted “fell short of the standards of his office and of the profession,” the court ordered. The Salem-based attorney’s brief contained “at least 15” fabricated citations and “at least nine purported” quotations that do not exist.
“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,” presiding judge Scott Shorr replied.
The case for which Ghiorso filed his opening brief — Doiban v. OLCC — came to be after the Oregon Liquor and Cannabis Commission (OLCC) revoked a marijuana production license against a man, Henry Doiban, who then missed a 15-minute window to show up for a remote hearing challenging the decision, according to The Oregonian.
Doiban reportedly blamed technological failures and asked Ghiorso to represent him in challenging the commission’s ruling. The attorney filed his brief in November 2024 but has noted that “he was having serious health issues” at the time and had already “exhausted the available extensions” to file. So, he said, he delegated responsibilities, and “his staff turned to search engines such as Google and Safari,” leading them to what they believed was “legitimate legal analysis.”
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.
