A federal judge in Portland says he will sanction lawyers who submitted a brief to him quoting a fake legal citation and what he called a “hallucinated” case.

The judge’s admonition follows an ethics opinion the Oregon State Bar issued earlier this year addressing the use of artificial intelligence tools in law practice.

U.S. District Judge Michael H. Simon spotted the “totally fake” citation in a trademark infringement case brought by lawyers for the non-profit Green Building Initiative.

The nonprofit referenced a 2021 case called “Stell v. Cardenas,” but Simon quickly identified it as a “hallucinated” case, with no parties named Stella or Cardenas in any case in the “District of Oregon or elsewhere.”

What also jumped out to Simon in the lawyers’ citation was the number provided for

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