- Companion case to Witkins. $500 sanction with leave to correct, decided same June 2026 sitting.
- Demonstrates the Oregon Supreme Court's two-track approach: dismissal where the merit hinges on the fabrication; monetary sanction where it does not.
- Procedurally distinguishable from Mata-line sanctions: the $500 figure tracks the modest end of the federal range.
- Reinforces that the verification duty applies on both sides of any caption.
Aldridge v. Tussing.
AI-fabricated citations in a respondent's filing warrant a monetary sanction under the court's inherent power. Unlike the parallel petitioner-side case of Witkins v. McGreevy, the court permitted resubmission of corrected filings rather than dismissing the matter outright, reflecting the procedurally different posture of a respondent's materials.
What happened. #
A respondent's filing in a separate Oregon Supreme Court matter contained citations to cases that could not be located in the Oregon Reports or the Oregon Appellate Reports, and quoted passages that did not appear in any real opinion. The court ordered the respondent to show cause and ultimately imposed a $500 monetary sanction. The court permitted the respondent to resubmit corrected filings.
The holding. #
AI-fabricated citations in a respondent's filing warrant a monetary sanction under the court's inherent power. Unlike the parallel petitioner-side case of Witkins v. McGreevy, the court permitted resubmission of corrected filings rather than dismissing the matter outright, reflecting the procedurally different posture of a respondent's materials.
The court's reasoning. #
The court treated the fabrication as a discrete procedural violation rather than an obstacle to the underlying merits. The respondent's position was severable from the specific fabricated authorities, so the practical relief of allowing corrected filings did not undermine the sanction. The $500 figure is in line with the lower end of the post-Mata federal sanctions range and signals the court's view that the conduct was discipline-adjacent rather than dispositive of the matter.
Operational implications. #
Read together with Witkins, Aldridge shows that the Oregon Supreme Court is calibrating the sanction to procedural impact: dismissal when the fabrication carries the petition; monetary penalty when it does not. For firms, the operational implication is that even when the underlying matter survives, the lawyer carries an order. Court records are public; sanctions orders are discoverable. The reputational sanction tracks the lawyer through every subsequent representation and every state-bar inquiry.
Primary sources. #
This is a case brief, not legal advice. Dan Hughes is not an attorney; IXSOR does not provide legal services.