Sanction teardown · Queensland IRC, Australia · 2025-02-13
Goodchild v State of Queensland
What happened
In Queensland IRC, Australia, a filing relied on "Internet searches" to help draft legal argument. The court identified the following problems with the citations in that filing:
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Fabricated (Case Law)Applicant cited a non-existent Fair Work Commission decision to justify an extension of time; searches found no such case and Applicant admitted sourcing via general internet searches; court gave it no weight.
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Fabricated (Case Law)Applicant relied on a non-existent FWC case to support her position; the Commission could not locate it and the Applicant later acknowledged sourcing errors; given no weight.
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Fabricated (Case Law)Applicant cited a fabricated FWC authority; Commission's searches failed to identify any such decision; Applicant conceded citation issues; no weight given.
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Fabricated (Case Law)Applicant referenced a non-existent FWC decision; court could not locate it and treated it as unreliable after Applicant's admission; no weight given.
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Fabricated (Case Law)Applicant invoked a fabricated FWC matter; not found on legal databases or the FWC website; Applicant admitted sourcing via general internet searches; court disregarded it.
Which AI tool
"Internet searches". 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
Relevant submissions ignored
Additional detail
"The Commission accepts the Applicant's explanation. Given that there appears to be significant doubt over whether the authorities cited by the Applicant represent actual decisions from the Fair Work Commission, I will give the authorities cited by the Applicant no weight in determining whether she has provided an explanation for the delay. This appears to be a salutary lesson for litigants in the dangers of relying on general search engines on the internet or artificial intelligence when preparing legal documents."
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/550/Goodchild_v_State_of_Queensland_Australia_13_February_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).