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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 85/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Schoene v. Oregon Department of Human Services
D. Oregon · Jun 25, 2025
OR / federalEditorial impact: lowpro sefake citationscivil rightstrial
Direct answer
What happened in this matter?
Fabricated: Case Law | Plaintiff cited Hampton v. City of Oregon City, which the Court stated does not exist and identified as an apparent AI-generated false citation. Outcome: Warning. "Before addressing the merits of Schoene’s motion, the Court notes that Schoene cited several cases in her reply brief to support her motion to amend, including Butler v. Oregon, 218 Or. App. 114 (2008), Curry v. Actavis, Inc., 2017 LEXIS 139126 (D. Or. Aug. 30, 2017), Estate of Riddell v. City of Portland, 194 Or. App. 227 (2004), Hampton v. City of Oregon City, 251 Or. App. 206 (2012), and State v. Burris, 107 Or. App. 542 (1991). These cases, however, do not exist.…
- Why the court cared
- The record concerns whether authorities presented to the decision-maker existed and could be verified. The tracked outcome is Warning; the linked source controls the precise reasoning.
- Why it matters now
- This matter connects pro se and fake citations involving AI (implied, unspecified) with Warning in D. Oregon, making it a concrete reference point for verification, supervision, and response controls.
Why this matter is tracked
Fabricated: Case Law | Plaintiff cited Hampton v. City of Oregon City, which the Court stated does not exist and identified as an apparent AI-generated false citation. Outcome: Warning. "Before addressing the merits of Schoene’s motion, the Court notes that Schoene cited several cases in her reply brief to support her motion to amend, including Butler v. Oregon, 218 Or. App. 114 (2008), Curry v. Actavis, Inc., 2017 LEXIS 139126 (D. Or. Aug. 30, 2017), Estate of Riddell v. City of Portland, 194 Or. App. 227 (2004), Hampton v. City of Oregon City, 251 Or. App. 206 (2012), and State v. Burris, 107 Or. App. 542 (1991). These cases, however, do not exist. Schoene’s false citations appear to be hallmarks of an artificial intelligence (“AI”) tool, such as ChatGPT. It is now well known that AI tools “hallucinate” fake cases. See Kruse v. Karlen, 692 S.W.3d 43, 52 (Mo. Ct. App. 2024) (noting, in February 2024, that the issue of fictitious cases being submitted to courts had gained “national attention”).6 In addition, the Court notes that a basic internet search seeking guidance on whether it is advisable to use AI tools to conduct legal research or draft legal briefs will explain that any legal authorities or legal analysis generated by AI needs to be verified. The Court cautions Schoene that she must verify the accuracy of any future citations she may include in briefing before this Court and other courts"
Operational lesson
This matter connects pro se and fake citations involving AI (implied, unspecified) with Warning in D. Oregon, making it a concrete reference point for verification, supervision, and response controls.
Record details
OregonSingle-state evidence scope
CourtD. Oregon
Jurisdictionfederal
Circuit9th Circuit
DateJun 25, 2025
AI
AI toolAI (implied, unspecified)
Party typePro Se Litigant
OutcomeWarning
Known amountNot recorded
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Warning
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
5 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited Hampton v. City of Oregon City, which the Court stated does not exist and identified as an apparent AI-generated false citation.
- Fabricated: Case Law | Plaintiff cited State v. Burris, which the Court stated does not exist and identified as an apparent AI-generated false citation.
- Fabricated: Case Law | Plaintiff cited Butler v. Oregon, which the Court stated does not exist and identified as an apparent AI-generated false citation.
- Fabricated: Case Law | Plaintiff cited Curry v. Actavis, Inc., which the Court stated does not exist and identified as an apparent AI-generated false citation.
- Fabricated: Case Law | Plaintiff cited Estate of Riddell v. City of Portland, which the Court stated does not exist and identified as an apparent AI-generated false citation.
Questions this record answers
- What happened in Schoene v. Oregon Department of Human Services?
- Fabricated: Case Law | Plaintiff cited Hampton v. City of Oregon City, which the Court stated does not exist and identified as an apparent AI-generated false citation. Outcome: Warning. "Before addressing the merits of Schoene’s motion, the Court notes that Schoene cited several cases in her reply brief to support her motion to amend, including Butler v. Oregon, 218 Or. App. 114 (2008), Curry v. Actavis, Inc., 2017 LEXIS 139126 (D. Or. Aug. 30, 2017), Estate of Riddell v. City of Portland, 194 Or. App. 227 (2004), Hampton v. City of Oregon City, 251 Or. App. 206 (2012), and State v. Burris, 107 Or. App. 542 (1991). These cases, however, do not exist.…
- Why does Schoene v. Oregon Department of Human Services matter for legal AI risk?
- This matter connects pro se and fake citations involving AI (implied, unspecified) with Warning in D. Oregon, making it a concrete reference point for verification, supervision, and response controls.
- What does the public record establish about Schoene v. Oregon Department of Human Services?
- 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 Schoene v. Oregon Department of Human Services 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.