Incident Tracker / United States (state)
R. M. v. Mohr, 353 Or App 182 (2026), A188092
·Oregon Court of Appeals·US-STATEFine
In 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 authority, but reduced the amount for his apology and limited means, then affirmed on the merits.
- Court
- Oregon Court of Appeals
- Date
- 2026-09-23
- Who used the AI
- Litigant in person
- AI tool
- Artificial intelligence (admitted; tool unnamed)
- Conduct
- A self-represented respondent appealing a Family Abuse Prevention Act restraining order cited three fabricated cases in his opening brief and admitted they resulted from reliance on artificial intelligence.
- Outcome
- Fine
- Penalty
- US$250
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-10-05
What was fabricated or misused
- Three fabricated cases cited in the respondent's opening brief
What the court said
“Respondent filed a response in which he admitted that these fabrications were the result of his reliance on artificial intelligence.”
“Although we move forward with respondent’s opening brief on the merits, we disregard the fabricated authorities and any support for his arguments those authorities purport to provide.”
Timeline
- Appeal submitted on the briefs.
- Court affirmed the restraining order and directed the respondent to pay $250.
Why this case matters
The opinion applies the Oregon Court of Appeals' per-citation tariff from Ringo v. Colquhoun Design Studio ($500 per fabricated citation) to a self-represented party, then reduces it, matching earlier 2026 unpublished sanction orders. The court explains the cost to its own docket: show-cause orders and refiling decisions delay rulings for other litigants. It shows a settled, predictable response to AI-fabricated authority in that court.
Practice note
Self-represented parties in the Oregon Court of Appeals face a sanction for each fabricated authority, reduced only for prompt admission and limited means. Fabricated cases are disregarded, so any argument that depends on them fails. Each case cited should be found and read in an official reporter before filing.
Primary sources for this incident
Related regulation records for this incident
- Notice Regarding Court Imposition of Sanctions for Submission of Fabricated Authority Produced by AIOregon Court of Appeals · US-STATE
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “R. M. v. Mohr, 353 Or App 182 (2026), A188092”, safelegalai.com/tracker/r-m-v-mohr (accessed 2026-10-05). Data: CC BY 4.0.