Kelly Bartholomew v. Public Utility Commission of Oregon
CA Oregon · Apr 6, 2026
What happened in this matter?
The Oregon Court of Appeals dismissed the judicial review proceeding after the pro se petitioner submitted an opening brief containing at least 10 fabricated case citations generated through AI-assisted research tools. The court determined the conduct violated procedural rules but declined to impose monetary sanctions.
- Why the court cared
- The court reasoned that the submission of fabricated legal authority violates ORCP 17 C and ORAP 1.40(4), regardless of whether the party acted in bad faith or with intent to mislead. The court determined that the petitioner's lack of transparency regarding the source of the citations and the permeation of the brief with fake authority warranted dismissal.
- Why it matters now
- This case illustrates that courts may dismiss proceedings for the submission of AI-generated fabricated citations even in the absence of bad faith. It highlights the judiciary's focus on the integrity of legal filings over the petitioner's intent.
Why this matter is tracked
In this judicial review proceeding, the petitioner submitted an opening brief containing at least 10 fabricated case citations. The Oregon Court of Appeals issued a show cause order regarding potential sanctions for the submission of non-existent legal authority. Although the petitioner initially attributed the errors to secondary sources, she later acknowledged the use of AI-assisted research tools. The court found that the fabricated citations permeated the brief and supported incorrect legal propositions, violating court rules regarding professional conduct and brief preparation. While the court explicitly found no bad faith or intent to mislead, it determined the conduct was sanctionable. The court ultimately dismissed the judicial review proceeding, declining to impose additional monetary sanctions.
This case illustrates that courts may dismiss proceedings for the submission of AI-generated fabricated citations even in the absence of bad faith. It highlights the judiciary's focus on the integrity of legal filings over the petitioner's intent.
Record details
What the record establishes about AI use
Petitioner acknowledged the issues resulted from using AI-assisted research tools.
The court dismissed the judicial review proceeding following a show cause order and the petitioner's subsequent motion to dismiss.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Fabricated cases were used to support multiple incorrect legal propositions and each of petitioner's three assignments of error relied on fabricated authority.
- Fabricated: Case Law | Opening brief included at least 10 fabricated case citations identified by PUC; the court found fabricated legal authority permeated the brief.
- Fabricated: Case Law | Specific fabricated citation cited in the brief: 'McKay Creek Valley Ass’n v. Washington County, 309 Or App 112, 124-25, 482 P3d 827 (2021)'; petitioner later claimed she intended a different, real McKay Creek Valley case.
Questions this record answers
- What happened in Kelly Bartholomew v. Public Utility Commission of Oregon?
- The Oregon Court of Appeals dismissed the judicial review proceeding after the pro se petitioner submitted an opening brief containing at least 10 fabricated case citations generated through AI-assisted research tools. The court determined the conduct violated procedural rules but declined to impose monetary sanctions.
- Why does Kelly Bartholomew v. Public Utility Commission of Oregon matter for legal AI risk?
- This case illustrates that courts may dismiss proceedings for the submission of AI-generated fabricated citations even in the absence of bad faith. It highlights the judiciary's focus on the integrity of legal filings over the petitioner's intent.
- What does the public record establish about Kelly Bartholomew v. Public Utility Commission of Oregon?
- 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.
- Which source supports this Kelly Bartholomew v. Public Utility Commission of Oregon summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.