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Courts on AI / Fabricated or misquoted citations

Mary McGreevy v. Adam Witkin

Supreme Court of Oregon · State supreme courts · OR · · No. S072692 · order

On 2026-06-04, in Mary McGreevy v. Adam Witkin, Supreme Court of Oregon struck the response to the petition for review, imposed a $500 sanction, and granted judicial notice. A self-represented appellant filed a response using nonexistent or hallucinated authorities. The monetary component was $500.

Disposition
The court struck the response to the petition for review, imposed a $500 sanction, and granted judicial notice.
Recorded conduct
A self-represented appellant filed a response using nonexistent or hallucinated authorities. — outcome: sanctions; 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.

Petitioner on review filed a reply to the response that argued, among other things, that respondent on review’s "response relies on authorities that cannot be located in the Oregon Reports." On March 26, 2026, respondent on review filed a response to the reply that addressed petitioner's other arguments but did not address the assertion about fabricated authorities. On April 10, 2026, this court issued a show cause order directing respondent on review to confirm, under penalty of perjury, each of the citations in his response, to explain how any erroneous citations came to be included in the pleading, and to show cause why the court should not strike his response or impose other sanctions. On April 24, 2026, respondent on review complied with this court's order. The response addressed each of the fabricated authorities filed, explained that respondent had used generative artificial intelligence ("AI") to create the pleading, and asserted that respondent on review was unaware that generative AI could generate fictitious authorities and inaccurate legal arguments. ORDER STRIKING RESPONDENT’S RESPONSE TO PETITION FOR REVIEW, IMPOSING SANCTION, AND GRANTING PETITIONER'S MOTION TO TAKE JUDICIAL NOTICE Appellate Court Administrator, Appellate Court Records Section, Oregon Supreme Court 1163 State Street, Salem, Oregon 97301-2563 (503) 986-5555 Page 2 of 3 Respondent on review stipulates that a financial sanction of $500 is appropriate.

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