Schoene v. Oregon Department of Human Services
D. Oregon · Jun 25, 2025 · Michael H. Simon
What happened in this matter?
The court issued a warning to a pro se litigant after she submitted a brief containing five fabricated cases. The judge identified these as AI-generated hallucinations and cautioned the litigant that she must verify the accuracy of all future citations and legal analysis before filing documents with the court.
- Why the court cared
- The court reasoned that the cited cases did not exist and that their inclusion was a hallmark of AI hallucination, necessitating a warning to the litigant regarding the duty to verify AI-generated content.
- Why it matters now
- This case illustrates judicial oversight of pro se litigants using AI tools. It reinforces the standard expectation that all legal research, regardless of the tool used, must be independently verified for accuracy before submission to the court.
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"
This case illustrates judicial oversight of pro se litigants using AI tools. It reinforces the standard expectation that all legal research, regardless of the tool used, must be independently verified for accuracy before submission to the court.
Record details
What the record establishes about AI use
The court identified the false citations as hallmarks of an AI tool, such as ChatGPT.
The court addressed the use of AI-generated false citations while ruling on the plaintiff's motion to amend her complaint and the defendants' motion for summary judgment.
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?
- The court issued a warning to a pro se litigant after she submitted a brief containing five fabricated cases. The judge identified these as AI-generated hallucinations and cautioned the litigant that she must verify the accuracy of all future citations and legal analysis before filing documents with the court.
- Why does Schoene v. Oregon Department of Human Services matter for legal AI risk?
- This case illustrates judicial oversight of pro se litigants using AI tools. It reinforces the standard expectation that all legal research, regardless of the tool used, must be independently verified for accuracy before submission to the court.
- 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.