| Court - Judge Name |
Effective Date |
Applicable To | Categories |
Summary |
| D. Or. – Judge Michael H. Simon | 11/12/2025 | Generative AI | Generative AI Usage | In Green Bldg. Initiative, Inc. v. Peacock, No. 3:24-cv-298-SI, 2025 U.S. Dist. LEXIS 227071 (D. Or. Nov. 12, 2025), the court ordered plaintiff and its counsel to show cause why they should not be sanctioned for “using fake, or ‘hallucinated,’ case citations” in plaintiff’s reply brief in support of plaintiff’s motion for interim attorney fees. ECF 87. The plaintiff filed a response three declarations from plaintiff’s counsel. In the response, one attorney acknowledged that he was the “drafter and signer” of the brief containing “two hallucinated citations.” ECF 88 at 2. Specifically, he admitted that he used Microsoft Copilot “for ‘wordsmithing’ purposes only,” was not aware that Copilot had inserted cases into the brief, and had not “conduct[ed] a full review of the final product” before filing the brief. ECF 88 at 2. Plaintiff’s counsel further proposed “sanctions,” which they intended to enforce “even if not ordered by the Court,” including reimbursement of their client’s related attorney’s fees; educating the firm’s attorneys on GenAI and evaluate additional safeguards that can be implemented; reimbursement of the defendant’s related attorney’s fees; mandatory CLEs on GenAI for the offending attorney; and a $5,000 donation to the Campaign for Equal Justice. Id. at 3-4. The court determined that these remedial actions were satisfactory and declined to impose formal sanctions on plaintiff, the law firm, or the offending attorney. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| Bankr. D. Or. – Judge Teresa H. Pearson | 7/7/2025 | Generative AI | Generative AI Usage | In In re Perkins, 2025 Bankr. LEXIS 1627 (Bankr. D. Or. July 7, 2025), in response to the court’s order to show cause, the pro se debtor “admitted that he used artificial intelligence” to conduct research, resulting in cases that were “inaccurate, irrelevant, and useless.” In discussing the various AI-generated citations, the court noted that all parties—regardless of their status of representation—are required to verify the accuracy of all information asserted and cited to in their filings. Judge Pearson ultimately declined to impose sanctions under Rule 9011 of the Federal Rules of Bankruptcy Procedure regarding the assertion of arguments without legal support, as the case was dismissed for other reasons. |
| Requires Disclosure and/or Verification | ||||
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| D. Or. – Judge Michael H. Simon | 6/25/2025 | Generative AI | Generative AI Usage | In Schoene v. Or. Dep’t of Hum. Servs., 2025 WL 1755839 (D. Or. June 25, 2025), in which the pro se plaintiff filed a motion to amend her complaint, the court briefly noted that she “cited several cases in her reply brief . . . [that] do not exist” and which “appear to be hallmarks of an artificial intelligence (‘AI’) tool, such as ChatGPT.” Although Judge Simon did not impose sanctions on the plaintiff, he noted that “a basic internet search seeking guidance on whether it is advisable to use AI tools to conduct legal research or draft legal briefs will explain that any legal authorities or legal analysis generated by AI needs to be verified,” and cautioned the plaintiff to verify the accuracy of future citations. The court ultimately denied the motion to amend on other grounds after granting defendants’ motion for summary judgment. |
| Requires Disclosure and/or Verification | ||||
| Applies to AI Used for Filings/Drafting |
Oregon
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