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Egan v Commonwealth of Australia [2026] FCA 1104

Court
Federal Court of Australia
Jurisdiction
Australia
Decided
2026-08-11
AI tool
Unidentified
Outcome
Court noted and rejected AI-generated erroneous quotations and citations, ignored the applicant's unsolicited post-hearing email, allowed summary judgment for the Respondent; no professional sanction or monetary penalty imposed.
Monetary penalty
None reported

What was hallucinated

False Quotes: Case Law | Applicant relied on a purported quoted passage attributed to Taylor v Johnson that does not exist; Court checked reports and found the passage absent. || Fabricated: Case Law | Applicant cited various authorities and legislation in supplementary submissions that the Commonwealth identified as non-existent (fabricated) and required correction. || False Quotes: Case Law | Applicant included an incorrect quotation/recital from Alati v Kruger which was later corrected by the applicant after it was identified.

Details

The applicant (self-represented) admitted using generative AI in preparing supplementary submissions and filed a notice of corrections; the Commonwealth identified non-existent authorities and erroneous quotations. The Court found a prominent quoted passage attributed to Taylor v Johnson did not exist, identified other incorrect citations (including Alati v Kruger) and disregarded AI-generated material that was not relied upon. The judge emphasised the duty to verify authorities, struck certain AI-generated passages from consideration (and ignored a gratuitous post-hearing email), but imposed no professional or financial sanction.

Sanction teardown · Federal Court of Australia, Australia · 2026-08-11

Egan v Commonwealth of Australia [2026] FCA 1104

What happened

In Federal Court of Australia, 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:

  • False Quotes (Case Law)
    Applicant relied on a purported quoted passage attributed to Taylor v Johnson that does not exist; Court checked reports and found the passage absent.
  • Fabricated (Case Law)
    Applicant cited various authorities and legislation in supplementary submissions that the Commonwealth identified as non-existent (fabricated) and required correction.
  • False Quotes (Case Law)
    Applicant included an incorrect quotation/recital from Alati v Kruger which was later corrected by the applicant after it was identified.

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

Court noted and rejected AI-generated erroneous quotations and citations, ignored the applicant's unsolicited post-hearing email, allowed summary judgment for the Respondent; no professional sanction or monetary penalty imposed.

Additional detail

The applicant (self-represented) admitted using generative AI in preparing supplementary submissions and filed a notice of corrections; the Commonwealth identified non-existent authorities and erroneous quotations. The Court found a prominent quoted passage attributed to Taylor v Johnson did not exist, identified other incorrect citations (including Alati v Kruger) and disregarded AI-generated material that was not relied upon. The judge emphasised the duty to verify authorities, struck certain AI-generated passages from consideration (and ignored a gratuitous post-hearing email), but imposed no professional or financial sanction.

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/2806/Egan_v_Commonwealth_of_Australia_2026_FCA_1104.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2806/Egan_v_Commonwealth_of_Australia_2026_FCA_1104.pdf

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