Couvrette v. Wisnovsky, No. 1:21-cv-00157-CL (D. Or.)
sanctions
In the US District Court for Oregon, lead counsel Stephen Brigandi filed three briefs with fifteen non-existent cases and quotations falsely attributed to eight real authorities, then concealed them. Magistrate Judge Mark D. Clarke dismissed the claims, imposed $15,500 in sanctions plus $94,704 in fees (~$110,000 total, shared with local counsel), and referred Brigandi to the Oregon State Bar.
- Date of decision/order
- 2025-12-12
- Court
- US District Court, District of Oregon (Medford Division)
- Jurisdiction
- US-FEDERAL
- AI tool
- Not identified in the record
- Conduct
- Lead counsel Stephen Brigandi filed three summary-judgment briefs containing fifteen non-existent cases and fabricated quotations falsely attributed to eight real authorities, generated by generative AI. When defendants flagged the fakes, the amended briefs deceptively deleted only the quotation marks rather than correcting the fabrications. Magistrate Judge Mark D. Clarke imposed terminating sanctions; the court denied Plaintiffs' motion for reconsideration on 22 June 2026, leaving the sanctions in place.
- Consequence
- USD 110,204
- Regulatory outcome
- Oregon State Bar: The court directed the Clerk to transmit its 12 December 2025 sanctions order to the Oregon State Bar (Brigandi appeared pro hac vice and is a California attorney). Referral only — no Bar disposition is yet on record. (2025-12-12)
Sources
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Cite this incident
SafeLegalAI Global Legal AI Incident Tracker, "Couvrette v. Wisnovsky, No. 1:21-cv-00157-CL (D. Or.)", safelegalai.com/tracker/couvrette-v-wisnovsky (accessed 2026-07-16). Data: CC BY 4.0.