Was R. M. v. Mohr sanctioned over AI-generated citations?

R. M. v. Mohr (CA Oregon, September 23, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Monetary penalty: $250 payable to the Appellate Court Services Division of the Oregon Judicial Department, reduced from the $1,500 proposed in the show-cause order; cited authorities disregarded; order affirmed. $250 in monetary penalties.

Which AI tool was involved in R. M. v. Mohr?

The order in R. M. v. Mohr does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

September 23, 2026 · AI sanctions database

R. M. v. Mohr

R. M. v. Mohr is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: CA Oregon
Date: September 23, 2026
Party: Pro Se Litigant
AI tool: Not identified in the order
Outcome: Monetary penalty: $250 payable to the Appellate Court Services Division of the Oregon Judicial Department, reduced from the $1,500 proposed in the show-cause order; cited authorities disregarded; order affirmed
Penalty: $250 in monetary penalties.

Fine

What the record shows

The Oregon Court of Appeals found that a self-represented respondent's opening brief in a restraining-order appeal cited three cases the court described as fabricated. It issued an order to show cause proposing a $1,500 sanction, or $500 per authority. The respondent admitted the citations resulted from his reliance on artificial intelligence, apologized, and accepted responsibility; no specific tool was named. Citing his acknowledgment and limited financial resources, the court reduced the sanction to $250, disregarded the cited authorities, and affirmed the trial court on the merits.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗ · CourtListener record ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · CA Oregon

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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