An attorney in Salem, Oregon, has been ordered to pay a $10,000 fine after submitting a legal briefing containing fabricated citations and quotes generated by artificial intelligence (AI). The fine represents one of the largest penalties ever issued in Oregon for such a mistake—a stark warning for legal professionals relying on AI tools for research and documentation.

The case against attorney William Giorso

In a decision issued by Judge Scott Shore, attorney William Giorso was found to have submitted an opening brief citing at least 15 non-existent legal precedents and at least 9 fabricated quotations. These erroneous references were traced back to AI-generated content that Giorso and his staff had used in their research.

The court deemed these inaccuracies the result of "AI hallucinations," a phenomenon where an AI tool generates information that appears factual but is entirely fabricated. Judge Shore stated that the false citations and quotes were "contrived from thin air."

Interestingly, this case is not an isolated incident. Just last December, another Oregon attorney faced fines for submitting similar AI-generated errors. That case set a precedent for imposing fines ranging from $500 to $1,000 per individual AI-related mistake.

How the errors occurred

Giorso argued that the errors were not intentional. He explained that his team had encountered limited relevant case law for their legal argument and turned to AI as part of their research process. By using AI to supplement traditional research, they unwittingly included fabricated legal analyses that misrepresented existing law.

The AI tool produced citations that appeared legitimate at first glance, which the team incorporated into their brief without realizing their inaccuracy. Giorso requested leniency from the court, citing new measures his firm has introduced to prevent similar errors in the future. These procedural changes reportedly contributed to the court's decision to reduce the fine from the minimum $16,500 penalty to $10,000. However, the imposed fine still marks the highest for an incident of this kind in the state.

AI and legal practice: A growing concern

The increasing reliance on AI tools in the legal field has brought efficiency gains but also heightened risks. While many AI programs excel at summarizing exhaustive legal documents or generating drafts, incidents like Giorso's highlight the vital need for human oversight. AI hallucinations can occur when AI tools lack sufficient training data or create plausible but entirely fabricated information to fill gaps—a significant issue when accuracy is paramount.

Legal professionals are now grappling with a new reality: AI can aid their work but cannot be an unchecked substitute for expertise and prudence. The legal system, built on precedent and accuracy, cannot accommodate false representations due to negligent AI usage.

Measures to prevent AI-induced errors

Judge Shore acknowledged that Giorso took steps to avoid similar issues in the future. Although no specifics on his firm's new procedures were revealed, common strategies for mitigating AI-related risks include:

• Cross-verifying AI-generated results: Always confirm AI-produced citations and content with trusted legal databases or case law repositories.
• Training staff on AI tools: Educate team members about AI’s capabilities, limitations, and potential risks.
• Combining AI and traditional research methods: AI tools should supplement rather than replace time-tested research practices.
• Establishing review protocols: Implement multi-stage review processes to ensure the accuracy of submitted documents.

These safety measures highlight the importance of responsible AI use. Courts are unlikely to excuse future offenders who fail to take similar precautions, especially as awareness of the risks of AI continues to grow.

Precedent in Oregon

Oregon’s legal community has been grappling with penalties for AI-related errors since late 2023, when the appellate court issued fines for similar conduct. Although that case involved smaller penalties of $500 to $1,000 per error, it set the tone for stricter enforcement. Giorso's penalty significantly exceeds those earlier fines, potentially signaling growing judicial intolerance for AI negligence.

Implications for the legal profession

This high-profile case underscores the stakes of using AI in the legal profession. While tools powered by artificial intelligence can streamline research and boost productivity, their uncritical use can lead to catastrophic outcomes—professional embarrassment, financial penalties, and even disciplinary action.

For lawyers, the case serves as a reminder that their professional obligations extend to all tools they employ, including emerging technologies. The introduction of AI tools into legal workflows must be tempered with skepticism, critical evaluation, and thorough verification. Courts are making it clear that they hold attorneys fully accountable for ensuring the accuracy of their work, regardless of whether mistakes originated from humans or software.

Key takeaway: AI assists, it doesn’t replace

Lawyers who choose to use AI must adopt clear safeguards to protect themselves and their clients. Although artificial intelligence offers a powerful resource, it must be seen as an assistive tool rather than a complete solution. The legal field still relies on careful human judgment—a factor no AI can replicate.

Oregon’s $10,000 penalty for attorney Giorso highlights the consequences of unverified AI usage in high-stakes environments. For the legal profession as a whole, the takeaway is clear: treat AI outputs with the same level of scrutiny as any other source.

FAQ

What is an AI hallucination? An AI hallucination refers to instances where generative AI produces plausible-sounding but entirely fabricated information. This occurs due to gaps in training data or misinterpretation of context.

Why was William Giorso fined? Giorso was fined $10,000 for submitting a legal briefing with fabricated citations and quotes generated by AI. These inaccuracies violated professional standards and undermined the integrity of the court's proceedings.

What steps can lawyers take to avoid AI errors? Lawyers can mitigate AI-related risks by cross-checking AI-generated content, blending AI use with traditional research, training their teams on AI limitations, and implementing rigorous document review protocols.

Is this the largest AI-related fine in Oregon? Yes. The $10,000 penalty against Giorso is the largest fine in Oregon to date for errors related to AI usage in legal practice.

Are similar cases common? Cases involving AI-related errors in legal filings are becoming more common as attorneys increasingly turn to AI tools. Courts have begun fining those who fail to verify the accuracy of AI-generated content.