What was hallucinated

Outdated Advice: Overturned Case Law | Respondent cited 'Bassola v Bassola (No 2) [1985] FamCA 33; (1985) FLC 91-629' and relied on it for the proposition that honest filing is not abuse; the court treated this as a mischaracterisation of Re Bassola and noted it was overturned on appeal. || Misrepresented: Exhibits & Submissions | Multiple other inapt and inaccurate references in the respondent's submissions produced by a generative AI program, leading to unreliable authorities throughout the submissions. || Fabricated: Case Law | Respondent cited a family-law 'Gould' authority (purported citation used to argue 'honest belief in necessity' negates abuse) that the court could not locate or that was misapplied.

Sanction teardown · FCA, Australia · 2025-12-08

Chu v Darmali

What happened

In FCA, 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:

Outdated Advice (Overturned Case Law)

Respondent cited 'Bassola v Bassola (No 2) [1985] FamCA 33; (1985) FLC 91-629' and relied on it for the proposition that honest filing is not abuse; the court treated this as a mischaracterisation of Re Bassola and noted it was overturned on appeal.
Misrepresented (Exhibits & Submissions)

Multiple other inapt and inaccurate references in the respondent's submissions produced by a generative AI program, leading to unreliable authorities throughout the submissions.
Fabricated (Case Law)

Respondent cited a family-law 'Gould' authority (purported citation used to argue 'honest belief in necessity' negates abuse) that the court could not locate or that was misapplied.

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.

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Source: https://www.damiencharlotin.com/documents/1316/Chu_v_Darmali_Australia_8_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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