Ringo v. Colquhoun Design Studio, LLC
Oregon Court of Appeals · Or. Ct. App. · Oregon bar guidance
Verified April 24, 2026
- Citation
- Ringo v. Colquhoun Design Studio, LLC, 345 Or App 301 (Dec. 3, 2025)
- Decided
- December 3, 2025
Summary
Respondents' attorney Gabriel A. Watson filed an answering brief in this appeal that contained two fabricated case citations (Claus v. Columbia State Bank, 275 Or App 113, 364 P3d 644 (2015) and Scheidler v. Ebin, 206 Or App 495, 503, 136 P3d 60 (2006)) and one fabricated block quotation attributed to McKeown v. McKeown, 317 Or App 616, 505 P3d 455 (2022). The Oregon Court of Appeals struck the brief and issued a show cause order. Counsel acknowledged hurried reliance on technology platforms but did not directly admit using AI; the court stated the fabricated law 'likely resulted from the use of artificial intelligence' and rejected the term 'hallucination' as obscuring the situation.
- AI tool:
- Generative AI (unspecified; court did not name a specific tool)
- Sanction amount:
- $2,000
What sanction did the court impose?
The Oregon Court of Appeals (Lagesen, C.J., for a panel including Egan, P.J. and Joyce, J.) sanctioned respondents' counsel $2,000, payable to the Appellate Court Services Division of the Oregon Judicial Department. The court applied a tariff of $500 per fabricated citation (two citations) and $1,000 per fabricated quotation or substantive statement of law (one fabricated quotation/statement). Respondents were granted 28 days to file a new answering brief; if filed by current counsel, the brief must include a certification that (1) counsel drafted the brief without using generative AI to produce a draft, (2) counsel has read each case and source cited, and (3) counsel has verified that every source cited, quoted, or paraphrased exists.
Why does Ringo v. Colquhoun Design Studio, LLC matter for law firms using AI?
Ringo is Oregon’s foundational case establishing sanctions tariffs for AI-hallucinated citations. The Court of Appeals held that an attorney who signs a brief containing fabricated law certifies its accuracy and bears financial liability. The $500-per-citation, $1,000-per-quotation tariff has become the standard in Oregon state appellate practice. The court also imposed a prospective certification requirement on the offending attorney: future briefs must include an affidavit that the brief was not drafted using generative AI and that all citations have been independently verified.