Tracked Changes, Wednesday, March 18, 2026
Oregon Court of Appeals sanctions a lawyer $10,000 for 15 fabricated citations found through web searches
On March 18, the Oregon Court of Appeals ordered petitioner's counsel in Doiban v. OLCC to pay $10,000. The brief cited at least 15 fabricated cases and at least nine quotations that do not exist. Counsel said staff found the citations through search engines and did not check them in Westlaw or Lexis. The court's formula would have produced at least $16,500, but it capped the sanction.
Sixth Circuit fines two lawyers $15,000 each over fake and misrepresented citations in appellate briefs
In Whiting v. City of Athens, decided March 13, the Sixth Circuit ordered attorneys Van R. Irion and Russ Egli to pay $15,000 each, cover the appellees' attorney fees on appeal, and pay double costs. The court found over two dozen fake or misrepresented citations. It made no express finding that AI was used, and referred the matter to the chief judge for possible discipline.
California bar committee proposes AI amendments to six Rules of Professional Conduct for public comment
At its March 13 meeting, the State Bar of California's Committee on Professional Responsibility and Conduct approved proposed AI amendments to rules 1.1, 1.4, 1.6, 3.3, 5.1 and 5.3 for 45 days of public comment, closing May 4. A proposed comment to Rule 3.3 would require lawyers to verify that cited authorities exist and are accurate. Another would require managerial lawyers to make reasonable efforts to set internal AI policies.
Legion, an AI platform for California litigators, adds a builder for motions and oppositions
Legion announced on March 16 its MPA Builder, which the company says turns case files into motions, oppositions, replies, mediation briefs, trial briefs and ex parte applications. Legion says it is built exclusively for California litigators and that the feature is available now to all its users. The announcement gives no price. Legion says users report up to 27% lower staffing costs.