Courts on AI / Fabricated or misquoted citations
Boersma v. Davenport
Oregon Court of Appeals · State appellate courts · OR · · 349 Or.App. 268, 2026 WL 1243999 · No. A186400 · opinion
The Oregon Court of Appeals on 2026-05-06 ordered the self-represented plaintiff to pay $500 for filing unverified or fabricated authorities in Boersma v. Davenport. The self-represented plaintiff filed an opening brief with one fabricated case citation and one mischaracterized case citation.
- Disposition
- The appeal was dismissed and Boersma was ordered to pay a $500 sanction to Appellate Court Services.
- Recorded conduct
- Boersma’s pro se opening brief contained several fabricated cases and unrelated cases after he was on notice of problems with his research and writing process. The court dismissed the appeal and imposed a $500 sanction. — outcome: fine; actor: litigant in person; $500
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
We issued an order to show cause “(1) why plaintiff's opening brief should not be stricken in part or in whole and (2) why this court should not, on its own motion, impose monetary sanctions for submitting briefing to this court that contained nonexistent case law. ” In plaintiff's response to the order to show cause, she claimed that she conducted her research in good faith despite limited access to legal research tools, did not intend to submit fabricated authority, and had been “subjected to heightened scrutiny for minor or correctable citation issues” while defendants relied on questionable legal authority without consequences in the trial court. She also pointed us toward her “prior experience regarding citation errors” as evidence that she has a history *270 of acting in good faith and being willing to correct errors once they are identified. Specifically, she pointed us toward her actions in a separate appeal before this court.