Bottrill v Graham & Anor (No 2)
Decided 2025-06-20 · Outcome: The second defendant's Notice of Motion for summary dismissal of the plaintiff’s claim was dismissed, with costs reserved to the trial judge. · AI tool: Unidentified.
1 sanctioned case on record in District Court of New South Wales where an attorney filed briefs, motions, or other pleadings containing AI-fabricated citations. Every entry below traces to a real, publicly reported court ruling. Data pulled daily from the underlying dockets and reporter databases — last update within 24 hours.
How courts in District Court of New South Wales have responded when a filing contained fabricated citations.
Filings in this jurisdiction most often cite the tool as “Implied” (the ruling describes an AI-generated brief but does not name a product).
The single documented sanction on record in District Court of New South Wales concluded with a The Second Defendant's Notice Of Motion For Summary Dismissal Of The Plaintiff’s Claim Was Dismissed, With Costs Reserved To The Trial Judge. tied to Unidentified as the implicated tool. One case is not a trend, but it establishes that this court has already surfaced the fabricated-citation issue on the docket — every subsequent filing in District Court of New South Wales is on notice.
The rulings in this jurisdiction are consistent with the pattern Citation Safe tracks nationally: when a court identifies a fabricated citation, the sanction almost always follows within days, not weeks. The attorney of record — not the AI — is on the hook. Rule 11 (federal), state analogs, and inherent authority all support monetary sanctions, disgorgement, adverse-costs orders, and bar referrals independent of the tool that produced the citation.
Practical implication: any brief that reaches a docket in District Court of New South Wales needs a citation-existence check before filing. Existence is Layer 1 — the case has to be real. Layer 2 is quote accuracy (any quoted language must actually appear in the opinion). Layer 3 is propositional support (the opinion must actually stand for what you cite it for). Every documented sanction below failed at Layer 1 or Layer 2 — the kind of failure that is trivially catchable before filing and catastrophically visible after.
Decided 2025-06-20 · Outcome: The second defendant's Notice of Motion for summary dismissal of the plaintiff’s claim was dismissed, with costs reserved to the trial judge. · AI tool: Unidentified.
Other courts on the Citation Safe sanctions database with a similar volume of AI-hallucination rulings on record.
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Informational only. Not legal advice. Data derived from public court records; corrections at /contact.