What was hallucinated

Misrepresented: Legal Norm | Applicant claimed Regulation 23 required the landing area to be outlined in red and neighbouring properties/contours shown; court held Reg 23 imposes no such obligation and the application concerned only the roofed bays. || Misrepresented: Legal Norm | Applicant grounded the JR on Article 40.4 personal liberty/property rights; court found Article 40.4 irrelevant to planning JR and no constitutional breach by the Board was alleged or evidenced. || Misrepresented: Legal Norm | Applicant invoked reckless endangerment under s.13 to stray golf balls; court treated these criminal law assertions as irrelevant and unsupported in the planning JR context. || Misrepresented: Legal Norm | Applicant accused the architect of 'subordination to perjury', a term the court noted is unfamiliar in Irish jurisprudence and likely AI-sourced, and entirely inappropriate. || Fabricated: Exhibits & Submissions | Applicant asserted the architect’s reference to a trustee letter was false because no such letter existed; court noted a date error explanation and treated the allegation as unfounded. || Misrepresented: Other | Applicant claimed the practice area since 2018 was unauthorised/a commercial driving range; court, relying on the Board’s addendum report, found the use authorised within existing permissions and non-commercial. || Fabricated: Other | Applicant alleged a 'suspiciously high' cancer rate around the course tied to environmental breaches; court found no evidence and described the claims as sensational and fear-inducing.

Details

AI UseJustice Nolan suspected that Reddan's submissions, especially references to "subornation to perjury" and Constitutional Article 40 rights, were AI-generated, exhibiting typical hallucination patterns (pseudo-legal concepts, inappropriate cut-and-paste fragments). Reddan did not admit using AI but relied on internet-sourced legal arguments that closely resembled LLM-style outputs.Hallucination DetailsInappropriate invocation of "subornation to perjury," a term foreign to Irish law. Constitutional and criminal law citations (Article 40, Non-Fatal Offences Against the Person Act) irrelevant to judicial review context. Assertions framed in hyperbolic, sensationalist terms without factual or legal basis. General incoherence of pleadings, consistent with AI-generated pseudo-legal textRuling/SanctionThe High Court refused leave to apply for judicial review on all nine grounds. While no formal financial sanction was imposed, Justice Nolan issued a sharp rebuke, highlighting the improper use of AI and warning against making scurrilous, unverified allegations in legal pleadings. The Court stressed that misuse of AI-generated material could itself amount to an abuse of the judicial process.

Sanction teardown · Ireland · 2025-03-13

Reddan & An Bord Pleanála v. Trustees of Nenagh Golf Club

What happened

In Ireland, 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:

Misrepresented (Legal Norm)

Applicant claimed Regulation 23 required the landing area to be outlined in red and neighbouring properties/contours shown; court held Reg 23 imposes no such obligation and the application concerned only the roofed bays.
Misrepresented (Legal Norm)

Applicant grounded the JR on Article 40.4 personal liberty/property rights; court found Article 40.4 irrelevant to planning JR and no constitutional breach by the Board was alleged or evidenced.
Misrepresented (Legal Norm)

Applicant invoked reckless endangerment under s.13 to stray golf balls; court treated these criminal law assertions as irrelevant and unsupported in the planning JR context.
Misrepresented (Legal Norm)

Applicant accused the architect of 'subordination to perjury', a term the court noted is unfamiliar in Irish jurisprudence and likely AI-sourced, and entirely inappropriate.
Fabricated (Exhibits & Submissions)

Applicant asserted the architect’s reference to a trustee letter was false because no such letter existed; court noted a date error explanation and treated the allegation as unfounded.
Misrepresented (Other)

Applicant claimed the practice area since 2018 was unauthorised/a commercial driving range; court, relying on the Board’s addendum report, found the use authorised within existing permissions and non-commercial.
Fabricated (Other)

Applicant alleged a 'suspiciously high' cancer rate around the course tied to environmental breaches; court found no evidence and described the claims as sensational and fear-inducing.

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

Application for Judicial Review Denied; Express Judicial Rebuke for Misuse of AI

Additional detail

AI UseJustice Nolan suspected that Reddan's submissions, especially references to "subornation to perjury" and Constitutional Article 40 rights, were AI-generated, exhibiting typical hallucination patterns (pseudo-legal concepts, inappropriate cut-and-paste fragments). Reddan did not admit using AI but relied on internet-sourced legal arguments that closely resembled LLM-style outputs.Hallucination DetailsInappropriate invocation of "subornation to perjury," a term foreign to Irish law. Constitutional and criminal law citations (Article 40, Non-Fatal Offences Against the Person Act) irrelevant to judicial review context. Assertions framed in hyperbolic, sensationalist terms without factual or legal basis. General incoherence of pleadings, consistent with AI-generated pseudo-legal textRuling/SanctionThe High Court refused leave to apply for judicial review on all nine grounds. While no formal financial sanction was imposed, Justice Nolan issued a sharp rebuke, highlighting the improper use of AI and warning against making scurrilous, unverified allegations in legal pleadings. The Court stressed that misuse of AI-generated material could itself amount to an abuse of the judicial process.

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/247/Reddan__An_Bord_Pleanala_v._Trustees_of_Nenagh_Golf_Club_Ireland_High_Court_March_13_2.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).