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Courts on AI / Fabricated or misquoted citations

Kelly Bartholomew v. Public Utility Commission of Oregon

Oregon Court of Appeals · State appellate courts · OR · · No. Order No. 25-125 · order

On 2026-04-06, Oregon Court of Appeals dismissed the judicial-review petition after the petitioner failed to explain fabricated AI-sourced citations in her opening brief and show-cause response. A self-represented party submitted a petition with 10 fabricated or nonexistent authorities, including Ass’n v. Washington County, 309 Or App 112, 124-25, 482 P3d 827.

Disposition
The court dismissed the judicial-review petition after the petitioner failed to explain fabricated AI-sourced citations in her opening brief and show-cause response.
Recorded conduct
The petition used 10 fabricated or nonexistent authorities, including Ass’n v. Washington County, 309 Or App 112, 124-25, 482 P3d 827, which the court found nonexistent, misquoted, or unsupported. — outcome: dismissal; actor: litigant in person
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.

still failed to acknowledge the egregiousness of her conduct and, instead, continued to minimize it. Nothing in petitioner’s response to the show cause order demonstrates, even an attempt at, transparency. Petitioner continued to avoid explaining how any of the fabricated case citations came to be, despite the fact that they are clearly the type of fake legal authority fabricated by artificial intelligence (AI) that the court has recently sanctioned. See Ringo, 345 Or App 301; Powell, 347 Or App 55. Petitioner attached to her response to the show cause order a copy of an email correspondence between herself and an assistant at the Law Library of Clackamas County, which demonstrate that petitioner had informed the library assistant that the case citations came from petitioner’s use of AI. Despite the emails, in her response to the show cause order petitioner maintained her vague argument that she used “secondary sources” to draft the brief. The court agrees with PGE that “to the extent that Petitioner’s non-existent citations resulted from the use of artificial intelligence (AI), she did not rely on a secondary source” and that petitioner’s “lack of transparency and candor should

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