Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 14, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · Federal Circuit and Family Court of Australia (Division 2), Australia · 2026-09-14

Dey v Minister for Immigration and Citizenship (No 2)

What happened

In Federal Circuit and Family Court of Australia (Division 2), Australia, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Six authorities cited in the judicial review submissions were admitted to be hallucinated after the Court questioned whether they existed. The Court treated their filing as improper conduct and a breach of the lawyer's duty to the Court.
Fabricated (Case Law)

Five authorities cited in the First Costs Submission were admitted to be hallucinated after the Court sought clarification. The submission was withdrawn, and the Court found that the AI-generated citations caused inconvenience, delay, and additional costs.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Personal costs order of AUD 9,600 against the lawyer; no referral to the regulator; lawyer publicly named and reprimanded through the reasons and orders. (monetary penalty: 1 .)

Additional detail

The lawyer admitted using generative AI to prepare judicial review submissions and a costs submission. The Court found that six authorities in the judicial review submissions and five authorities in the costs submissions were hallucinated, while other cited authorities did not support the propositions for which they were cited. The Court itself identified the problem and had to fact-check the submissions. It held that filing unverified or hallucinated authorities breached the lawyer's duty to the Court, caused delay and additional costs, and compromised the administration of justice. The Court ordered the lawyer to pay AUD 9,600 in costs, declined to refer him to the regulator, and publicly identified him in the judgment.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/3104/Dey_v_Minister_for_Immigration_and_Citizenship_14_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).