Home/ Incident database/oregon-brigandi-ai-sanctions-2026-04
Legal / liability Hallucinated action verified

Oregon federal judge sanctioned two lawyers $110,000 over AI-fabricated case citations

Couvrette v. Brigandi et al. (D. Ore.) · Apr 17, 2026 · General agent

What happened

U.S. Magistrate Judge Mark D. Clarke of the District of Oregon imposed $110,000 in fines and attorney fees against two lawyers who filed briefs filled with fake cases and fabricated quotations produced with AI assistance, calling the case 'a notorious outlier in both degree and volume' in the sanctions universe and dismissing the underlying $12 million elder-abuse winery dispute with prejudice. San Diego attorney Stephen Brigandi and Portland attorney Tim Murphy were sanctioned; the judge said AI tools were used to draft the briefs and that counsel's silence despite multiple opportunities to explain 'speaks volumes'. ABA Journal reported the penalty on April 17, 2026, citing the December 12 opinion.

$110K
Loss / impact
Apr 17
2026
Hallucinated
Failure mode
General
Agent type

Causal vector

AI-drafted filings entered a court record without verification: fabricated cases and quotes sailed past every human checkpoint to the most consequential venue possible

Source

Reported by ABA Journal. Verified against the primary report.

Read the original report ↗

How a spend firewall would have helped

Citations are to legal work what merchant allowlists are to payments: an agent output that must be verified against an authoritative source before it can move. The sanction is the price of shipping unverified agent output into a consequential system.

The six rule types that contain this class of failure

Per-transaction cap

Any single spend above your ceiling is BLOCKED before it moves.

Daily total

Cumulative spend across all agent calls, bounded per day.

Velocity limit

Stops runaway retry loops — the #1 cause of overnight losses.

Merchant allowlist

Only approved destinations can ever receive funds.

Category rules

Flag high-risk classes (crypto, infra, refunds) for review.

Approval threshold

Above a value, the action waits for a human.

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