What was hallucinated

Fabricated: Case Law | Ms Chen cited 'Peterson v Forbes 1997 2 NZLR 216 (CA)', which does not exist; the Court noted the closest real reported case was Tui Food Ltd v New Zealand Milk Corp Ltd [1997] 2 NZLR 214. || Fabricated: Case Law | Ms Chen cited 'Vélez v Ticketmaster NZ Limited 2023 NZSC 113', which does not exist; the Court noted the neutral citation [2023] NZSC 113 actually corresponds to Yan v Mainzeal Property and Construction Ltd (in liq). || Misrepresented: Case Law | Ms Chen relied on Dorchester Finance Ltd v Deloitte [2012] NZCA 226 as authority on CCCFA oppression, but the Court observed the real case is about contract interpretation and was mischaracterised.

Sanction teardown · Supreme Court, New Zealand · 2026-05-01

Chen v. Goodmore Investments & Tawa

What happened

In Supreme Court, New Zealand, 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)

Ms Chen cited 'Peterson v Forbes 1997 2 NZLR 216 (CA)', which does not exist; the Court noted the closest real reported case was Tui Food Ltd v New Zealand Milk Corp Ltd [1997] 2 NZLR 214.
Fabricated (Case Law)

Ms Chen cited 'Vélez v Ticketmaster NZ Limited 2023 NZSC 113', which does not exist; the Court noted the neutral citation [2023] NZSC 113 actually corresponds to Yan v Mainzeal Property and Construction Ltd (in liq).
Misrepresented (Case Law)

Ms Chen relied on Dorchester Finance Ltd v Deloitte [2012] NZCA 226 as authority on CCCFA oppression, but the Court observed the real case is about contract interpretation and was mischaracterised.

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

Not specified in source record.

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/2134/Chen_v._Goodmore_and_Tawa_NEW_2026-NZSC-40.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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