Oregon · state appellate court · 2026

R. M. v. Mohr

Court of Appeals of Oregon, 23 September 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Or. Ct. App.

  1. Court. Court of Appeals of OregonCOURT
  2. Level. state appellate courtLEVEL
  3. Date. 23 September 2026DATED
  4. Docket. No. A188092DOCKET
  5. Judge. TookeyJUDGE
  6. Reporter. 353 Or. App. 182CITE
  7. Documents. one document, 6 passages quoted belowON FILE
  8. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 23 September 2026 · source · PDF · 8 pages

As explained below, we affirm the trial court’s order. ARTIFICIAL INTELLIGENCE AND THE USE OF FABRICATED CASES We first address artificial intelligence and the use of fabricated cases by parties appearing before the Oregon Court of Appeals. The use of artificial intelligence by parties in a manner that results in fabricated cases being cited by parties has become, at times, a hindrance to this court’s core mission of fully considering the merits of each case, provid- ing a thorough and prompt review of issues raised by each case, and resolving cases for parties.

When parties use artificial intelligence that gen - erates fabricated legal authorities, and when they then set forth arguments based on those fabricated authorities, we cannot properly consider the issues presented by cases.

As a result, we are diverted from giving timely decisions to parties regarding the merits of their disputes. Here, respondent’s opening brief contained cita - tions to three fabricated cases. We issued an order to show cause why respondent’s brief should not be stricken and why sanctions should not be imposed in the amount of $1,500, or $500 for each fabricated authority.

T. v. Solis, 303 Or App 297, 298 n 1, 462 P3d 767 (2020), we stated in a footnote, “In civil restraining order cases, we ordinarily refer to the parties by their designation in the trial court.” Cite as 353 Or App 182 (2026) 185 (2025) (sanctioning party in the amount of “$500 for each fabricated citation and $1,000 for each false quotation or substantive statement of law”). Respondent filed a response in which he admitted that these fabrications were the result of his reliance on artificial intelligence.

Respondent apologized for including these citations in his brief and accepted full responsibility. We continue to emphasize the strain that the inclu- sion of fabricated authorities puts on our judicial system in that “[t]he time taken to address [a party’s] reliance on fabri- cated authority would have been far better utilized address- ing other matters.” Powell v. Employment Dept., 347 Or App 55, 60, 586 P3d 1257 (2026); see also Williams v.

OLCC, 347 Or App 742, 749, 587 P3d 435 (2026) (stating that petitioner’s inclusion of fabri - cated authority “has cost the court and respondent’s coun - sel substantial time and expense, pulling them and us away from other work in our justice system”); Ringo, 345 Or App at 304 (“Every hour spent addressing false citations and state- ments of law is an hour diverted from those matters in which attorneys have supported their arguments with precedent that exists,” and “[e]very single time a [party] relies on false authority, the court will need to take the time to address the situation to, at a minimum, ensure that the public retains confidence that the courts are not relying on fabricated […]

What the text mentions

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Where this fits

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More from Court of Appeals of Oregon, from Oregon, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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