Carol L. Williams v. Tracy Honl
CA Oregon · Apr 22, 2026
- Jurisdiction
- state
- Court
- CA Oregon
- Record ID
- carol-l-williams-v-tracy-honl-2026-04-22
- Observed outcome
- Opening brief stricken; appellant's attorneys ordered to pay $8,044.25 in attorney fees to respondent; leave granted to file an amended brief subject to strict verification certifications.
- Known monetary consequence
- $8,044
Why this matter warrants attention
The court struck the appellant's opening brief and ordered the appellant's attorneys to pay $8,044.25 in attorney fees to the respondent as a sanction for submitting fabricated legal authority generated by AI without verification.
The court reasoned that the submission of fabricated law, even if unintentional, prejudices the opposing party by forcing them to expend resources identifying and addressing nonexistent authority, and strains limited judicial resources. The court determined that an award of attorney fees under ORCP 17 D(4) was an appropriate sanction to reimburse the respondent for the burden caused by the false certification, while declining to dismiss the appeal because the conduct was unlikely to recur.
Strike-and-costs orders hit $8K fast; require second-attorney sign-off on every cited case before filing.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Tort
- Appellate
- Monetary
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- $8,044
- Procedural posture
- On order of the Oregon Court of Appeals following a show cause proceeding regarding the submission of fabricated legal authority in an opening brief.
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
The attorney admitted to using generative AI but the specific tool was not named.
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.
- Compare every quoted passage and pincite directly with the underlying opinion or 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.