Kelly Bartholomew v. Public Utility Commission of Oregon
CA Oregon · Apr 6, 2026
- Jurisdiction
- state
- Court
- CA Oregon
- Record ID
- kelly-bartholomew-v-public-utility-commission-of-oregon-2026-04-06
- Observed outcome
- The judicial review proceeding was dismissed by the court.
- Known monetary consequence
- $0
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Fake Citations
- Administrative
- Appellate
- Case Dismissed
- AI attribution
- Admitted
- Recorded tool
- AI-assisted research tools
- Known monetary consequence
- $0
- Procedural posture
- The court dismissed the judicial review proceeding following a show cause order and the petitioner's subsequent motion to dismiss.
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
Petitioner acknowledged the issues resulted from using AI-assisted research tools.
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
- Implement mandatory verification protocols for all case citations, regardless of the research tool used.
- Ensure pro se litigants are informed of the risks associated with AI-generated legal research.
- Review all filings for citation accuracy before submission to ensure compliance with local rules of appellate procedure.