Boersma v. Davenport
CA Oregon · May 6, 2026
- Jurisdiction
- state
- Court
- CA Oregon
- Record ID
- boersma-v-davenport-2026-05-06
- Observed outcome
- The appeal was dismissed, and the court imposed a $500 monetary sanction against the pro se litigant.
- Known monetary consequence
- $500
Why this matter warrants attention
The Oregon Court of Appeals imposed a $500 monetary sanction on a pro se litigant for including fabricated case law and mischaracterized authority in an appellate brief, finding that the litigant failed to verify citations despite prior notice of similar research deficiencies.
The court reasoned that the litigant was on notice regarding the potential for her research process to produce fabricated authority and failed to investigate or inform the court of citation issues, thereby wasting judicial resources in violation of ORCP 17 C(1).
This case illustrates the judicial response to pro se litigants using unverified, potentially AI-generated research. It reinforces that courts hold all parties responsible for the accuracy of their citations, regardless of research tool limitations.
Failure modes and consequences
- Pro Se
- Fake Citations
- Misrepresented Authority
- Tort
- Appellate
- Monetary
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- $500
- Procedural posture
- Appellate review of a trial court judgment, resulting in dismissal of the appeal and the sua sponte imposition of monetary sanctions.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Court noted litigant's research process produced fabricated authority.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.