What was hallucinated

Fabricated: Case Law | A case cited at para [27] of the applicant's original submissions was non-existent; the court found it was AI-generated and refused to reproduce it. Counsel admitted the citations came from an AI-generated Google summary. || Fabricated: Case Law | A second case cited at para [27] of the applicant's original submissions was non-existent; the court determined it was a hallucinated authority produced by AI and did not rely on it. || Fabricated: Case Law | A third case cited at para [27] of the applicant's original submissions was non-existent; the court treated it as an AI hallucination and the solicitors withdrew reliance on the citation.

Sanction teardown · Federal Circuit and Family Court, Australia · 2026-02-03

Pasuengos v Minister for Immigration and Citizenship (No 2)

What happened

In Federal Circuit and Family Court, 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:

Fabricated (Case Law)

A case cited at para [27] of the applicant's original submissions was non-existent; the court found it was AI-generated and refused to reproduce it. Counsel admitted the citations came from an AI-generated Google summary.
Fabricated (Case Law)

A second case cited at para [27] of the applicant's original submissions was non-existent; the court determined it was a hallucinated authority produced by AI and did not rely on it.
Fabricated (Case Law)

A third case cited at para [27] of the applicant's original submissions was non-existent; the court treated it as an AI hallucination and the solicitors withdrew reliance on the citation.

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

Bar Referral

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/1852/Pasuengos_v_Minister_for_Immigration_and_Citizenship_3_February_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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