Schoene v. Oregon Department of Human Services
D. Oregon · Jun 25, 2025 · Michael H. Simon
- Jurisdiction
- federal
- Court
- D. Oregon
- Record ID
- schoene-v-oregon-department-of-human-services-2025-06-25
- Observed outcome
- The court issued a warning to the pro se litigant regarding the submission of AI-generated false citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Fake Citations
- Civil Rights
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- AI (e.g., ChatGPT)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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 court identified the false citations as hallmarks of an AI tool, such as ChatGPT.
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.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.