Skip to content

Incident Tracker / United States (state)

Bartholomew v. Public Utility Commission of Oregon

·Court of Appeals of the State of Oregon·US-STATEDismissalprovisional

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.

Court
Court of Appeals of the State of Oregon
Date
2026-04-06
Who used the AI
Litigant in person
AI tool
Not identified in the record
Conduct
Petitioner’s opening brief cited about 25 cases, at least 10 of which were fabricated; the fabricated authorities supported multiple incorrect propositions and each assignment of error.
Outcome
Dismissal
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Provisional — written by the court-decisions pipeline, awaiting the editor
Last checked
2026-09-07

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

Similar incidents on the record

  • Tapscott v. Fariss, No. 25-1666 (Iowa Ct. App. 2026)2026-10-07 · Court of Appeals of Iowa · DismissalIn the Court of Appeals of Iowa, a self-represented appellant's final brief in a protective-order appeal contained multiple hallucinated case citations. After two earlier briefs were struck and the appellant failed to a…
  • Washington v. Justice, No. 2D2025-2678 (Fla. 2d DCA 2026)2026-10-07 · District Court of Appeal of Florida, Second District · DismissalIn Florida's Second District Court of Appeal, self-represented appellants filed a brief citing eleven cases the court could not find and likely generated by AI. After an unavailing show-cause response and a pattern of f…
  • Shannon v. Shannon, 322 Neb. 451 (2026), No. S-25-5462026-10-02 · Nebraska Supreme Court · Filing struckIn Nebraska, the state Supreme Court struck a self-represented divorce litigant's appellate brief for fictitious citations produced by his admitted AI use. Extending Prososki v. Regan to unrepresented parties, it held s…
  • R. M. v. Mohr, 353 Or App 182 (2026), A1880922026-09-23 · Oregon Court of Appeals · FineIn Oregon, the Court of Appeals ordered a self-represented restraining-order appellant to pay $250 after his brief cited three fabricated cases he admitted came from AI. The court had threatened $1,500, at $500 per fake…

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Bartholomew v. Public Utility Commission of Oregon”, safelegalai.com/tracker/kelly-bartholomew-v-public-utility-commission-of-oregon (accessed 2026-10-07). Data: CC BY 4.0.

Report an issue with this record →