loading . . . Another Oregon attorney has been bamboozled by the incorrect output of artificial intelligence — and the state’s appellate court has slapped him with a record fine.
The Oregon Court of Appeals issued a $10,000 fine to Bill Ghiorso, a Salem-based civil attorney, after determining he signed his name to a legal brief containing 15 bogus citations and nine quotes “that had been contrived from thin air.”
Ghiorso challenged the fee, arguing he didn’t “knowingly” include false material in his filings, but instead had relied on a paralegal’s research. But the appellate court rejected that argument.
“Counsel at least should have known… that submitting a brief with unchecked and ultimately fabricated citations may breach an attorney’s duties of professionalism, truthfulness and candor to the court,” Presiding Judge Scott Shorr wrote in the March 18 opinion.
The appeals court set the precedent for A.I. errors in December when it tagged a different civil attorney with a $2,000 fine and created a fee schedule of $500 to $1,000 per artificial error. Following those rules, Ghiorso’s bill could have totaled as much as $16,500, according to Shorr. But the presiding judge said the court would cap its fees at $10,000 because Ghiorso has recently had medical trouble.
The $16,500 potential fine is the largest an Oregon attorney has racked up so far for errors created by use of generative A.I., a newfound technology which effortlessly churns out reams of seemingly plausible text, but has no innate fidelity to the truth.
Appellate judges have issued only one other financial penalty for erroneous A.I. use this year, when they fined Keith E. Powell, who represented himself in an employment board case, $500 in February.
The recent ruling against Ghiorso stemmed from a marijuana production license revoked by the Oregon Liquor and Cannabis Commission in 2022. Henry Doiban, the licensee, had missed the 15-minute window to appear at a remote hearing contesting the agency’s decision.
Doiban blamed technology troubles for his failure to appear, and hired Ghiorso to challenge the OLCC’s ruling.
Ghiorso wrote that he only had a day to write the AI-assisted memo on a relatively new branch of the law. However court records show Ghiorso had asked for a half-dozen delays to file his opening brief in the appellate case, and that he ultimately set Nov. 4, 2024 as a self-imposed final deadline.
The Salem attorney said his paralegal turned to Google to do research for the memo and apparently found content created by A.I.
Google results often include A.I. summaries generated by the search engine.
“If one asks Google’s search engine whether many of the fabricated cases are real, it will generate a response… affirming that the fabricated cases are in fact real,” Ghiorso explained. “This reliance was a fundamental error.”
Patricia Rincon, an assistant Oregon attorney general representing the OLCC, noted that she had flagged the errors in Ghiorso’s brief seven months before the appellate court noted the issue during oral arguments in November 2025. Rinco said Ghiorso didn’t respond to her email.
In a brief to the appellate court, Ghiorso apologized for the mistakes, saying they “fell short of the standards of my office and of the profession.”
He did not respond to a request for comment.
_This article wasoriginally published by The Oregonian/OregonLive and is reprinted with permission._
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##### Zane Sparling - The Oregonian/OregonLIve https://www.salemreporter.com/2026/03/25/salem-attorney-slapped-with-record-fine-after-citing-case-law-hallucinated-by-ai/
