What was hallucinated

Fabricated: Case Law | Claimant cited a non-existent Industrial Court case to support an implied post-training obligation; Court found it lacked proper citation, was inconsistent with Industrial Court party practice, not in databases, and not in the bundle. || Fabricated: Case Law | Claimant cited a Trinidad and Tobago case that the Court could not locate in any recognised database and which lacked proper citation; treated as non-existent. || Fabricated: Case Law | Claimant relied on this UK authority; the Court noted the citation was not verifiable in recognised databases and treated it as non-existent. || Fabricated: Case Law | Claimant cited this case; the Court could not verify its existence in any database and it was not provided in the bundle. || Fabricated: Case Law | Claimant cited this authority; the Court found it lacked a proper citation, could not be found in any recognised database, and was not in the bundle. || Fabricated: Case Law | Claimant cited this case; the Court determined it does not appear to exist and was unsupported by any database or bundle materials. || Misrepresented: Case Law | Claimant relied on this case to support the implied term proposition, but the Court noted it concerns medical negligence and not employer-funded training.

Details

AI UseCounsel denied using AI directly and attributed the hallucinations to “Google and Google Scholar” searches by a junior research assistant. However, the court found the citation pattern highly characteristic of generative AI hallucinations, including plausible-sounding but non-existent authority names and improper formatting. Counsel acknowledged a lack of adequate supervision and admitted that the cited authorities were never verified nor included in the bundle.Hallucination DetailsSeven cited authorities were found to be fictitious or mischaracterized, including:BWIA v. Ramnarine (TT Industrial Court, 2005)National Petroleum Marketing Co. v. Brewster (TT 2007)Horner v. KMW [2000] IRLR 814Jones v. Manchester Corporation [1952] 2 QB 852 (used for unrelated point)London School of Economics v. Dr Don [2016] EATIshmael v. NIPDEC (TT, 2014)BWIA v. Hollis (TT, 2001)These were used to support the implied obligation to repay employer-sponsored training, the core issue of the case. None were available in legal databases or official archives, and no hard copies were ever submitted.Ruling/SanctionWhile the court awarded judgment for the Claimant on the breach of contract claim, it found the citation misconduct egregious and referred the matter to the Disciplinary Committee of the Law Association. The Court noted that hallucinated citations undermine judicial integrity and must be proactively prevented.Key Judicial ReasoningJustice Westmin James emphasized that lawyers must not submit unverifiable or fictitious authority, whether generated by AI or not. He underscored that the legal system depends on the accuracy of submissions, and that even unintentional use of hallucinated material violates the duty of candour and may constitute professional misconduct.

Sanction teardown · High Court of Justice, Trinidad & Tobago · 2025-04-30

Nexgen Pathology Services Ltd v. Darcueil Duncan

What happened

In High Court of Justice, Trinidad & Tobago, 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)

Claimant cited a non-existent Industrial Court case to support an implied post-training obligation; Court found it lacked proper citation, was inconsistent with Industrial Court party practice, not in databases, and not in the bundle.
Fabricated (Case Law)

Claimant cited a Trinidad and Tobago case that the Court could not locate in any recognised database and which lacked proper citation; treated as non-existent.
Fabricated (Case Law)

Claimant relied on this UK authority; the Court noted the citation was not verifiable in recognised databases and treated it as non-existent.
Fabricated (Case Law)

Claimant cited this case; the Court could not verify its existence in any database and it was not provided in the bundle.
Fabricated (Case Law)

Claimant cited this authority; the Court found it lacked a proper citation, could not be found in any recognised database, and was not in the bundle.
Fabricated (Case Law)

Claimant cited this case; the Court determined it does not appear to exist and was unsupported by any database or bundle materials.
Misrepresented (Case Law)

Claimant relied on this case to support the implied term proposition, but the Court noted it concerns medical negligence and not employer-funded training.

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 referred the matter to the Disciplinary Committee

Additional detail

AI UseCounsel denied using AI directly and attributed the hallucinations to “Google and Google Scholar” searches by a junior research assistant. However, the court found the citation pattern highly characteristic of generative AI hallucinations, including plausible-sounding but non-existent authority names and improper formatting. Counsel acknowledged a lack of adequate supervision and admitted that the cited authorities were never verified nor included in the bundle.Hallucination DetailsSeven cited authorities were found to be fictitious or mischaracterized, including:BWIA v. Ramnarine (TT Industrial Court, 2005)National Petroleum Marketing Co. v. Brewster (TT 2007)Horner v. KMW [2000] IRLR 814Jones v. Manchester Corporation [1952] 2 QB 852 (used for unrelated point)London School of Economics v. Dr Don [2016] EATIshmael v. NIPDEC (TT, 2014)BWIA v. Hollis (TT, 2001)These were used to support the implied obligation to repay employer-sponsored training, the core issue of the case. None were available in legal databases or official archives, and no hard copies were ever submitted.Ruling/SanctionWhile the court awarded judgment for the Claimant on the breach of contract claim, it found the citation misconduct egregious and referred the matter to the Disciplinary Committee of the Law Association. The Court noted that hallucinated citations undermine judicial integrity and must be proactively prevented.Key Judicial ReasoningJustice Westmin James emphasized that lawyers must not submit unverifiable or fictitious authority, whether generated by AI or not. He underscored that the legal system depends on the accuracy of submissions, and that even unintentional use of hallucinated material violates the duty of candour and may constitute professional misconduct.

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/436/Nexgen_Pathology_Services_v._Darcueil_Duncan_Trinidad__Tobago_April_30_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).