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Kuzniar v General Dental Council

Court
Employment Tribunal
Jurisdiction
UK
Decided
2025-08-15
AI tool
ChatGPT
Outcome
Tribunal declined to award costs
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Claimant's skeleton arguments and authority bundles contained 15 authorities identified by Respondent as non-existent (mixes of real names and non-existent citations); Respondent could not locate them. || Misrepresented: Case Law | Claimant relied on 13 authorities that do exist but were found not to support the propositions asserted (misattributed/irrelevant authorities). || False Quotes: Case Law | Claimant cited a quotation attributed to Yerrakalva v Barnsley MBC [2012] EWCA Civ 1399 that is not found within that judgment.

Sanction teardown · Employment Tribunal, UK · 2025-08-15

Kuzniar v General Dental Council

What happened

In Employment Tribunal, UK, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Claimant's skeleton arguments and authority bundles contained 15 authorities identified by Respondent as non-existent (mixes of real names and non-existent citations); Respondent could not locate them.
  • Misrepresented (Case Law)
    Claimant relied on 13 authorities that do exist but were found not to support the propositions asserted (misattributed/irrelevant authorities).
  • False Quotes (Case Law)
    Claimant cited a quotation attributed to Yerrakalva v Barnsley MBC [2012] EWCA Civ 1399 that is not found within that judgment.

Which AI tool

ChatGPT. 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

Tribunal declined to award costs

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://naturalandartificiallaw.com/false-citations-ai-hallucinations-uk-2/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://naturalandartificiallaw.com/false-citations-ai-hallucinations-uk-2/

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