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Tekla & Tekla

Court
Federal Circuit and Family Court
Jurisdiction
Australia
Decided
2025-12-23
AI tool
Implied
Outcome
—
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Appellant cited a non-existent case 'Dogan & Dogan' (said to be Family Court of Australia, 2004); court noted it does not exist and omitted it from reasons. || Fabricated: Case Law | Appellant relied on 'Duncan & Duncan' with a 2016 citation which does not exist; court identified it as a fabricated authority. || Fabricated: Case Law | Appellant relied on 'Tindal & Tindal' with a 2007 citation which does not exist; court identified it as fabricated. || False Quotes: Case Law | Appellant attributed a proposition to Penfold v Penfold that the case does not contain (claimed that costs orders should not impose undue hardship); court noted incorrect citation and misstatement of authority. || Misrepresented: Case Law | Appellant misstated the House v The King test, describing legal unreasonableness as a test of 'fairness'; court identified this as an incorrect statement of the precedent. || Misrepresented: Case Law | Appellant cited Jurchenko & Foster [2014] FamCAFC 127 with an incorrect citation and relied on it to support family violence despite that case rejecting the claims; court noted the incorrect citation and misapplication.

Sanction teardown · Federal Circuit and Family Court, Australia · 2025-12-23

Tekla & Tekla

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)
    Appellant cited a non-existent case 'Dogan & Dogan' (said to be Family Court of Australia, 2004); court noted it does not exist and omitted it from reasons.
  • Fabricated (Case Law)
    Appellant relied on 'Duncan & Duncan' with a 2016 citation which does not exist; court identified it as a fabricated authority.
  • Fabricated (Case Law)
    Appellant relied on 'Tindal & Tindal' with a 2007 citation which does not exist; court identified it as fabricated.
  • False Quotes (Case Law)
    Appellant attributed a proposition to Penfold v Penfold that the case does not contain (claimed that costs orders should not impose undue hardship); court noted incorrect citation and misstatement of authority.
  • Misrepresented (Case Law)
    Appellant misstated the House v The King test, describing legal unreasonableness as a test of 'fairness'; court identified this as an incorrect statement of the precedent.
  • Misrepresented (Case Law)
    Appellant cited Jurchenko & Foster [2014] FamCAFC 127 with an incorrect citation and relied on it to support family violence despite that case rejecting the claims; court noted the incorrect citation and misapplication.

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

Not specified in source record.

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/1322/Tekla__Tekla_Australia_23_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1322/Tekla__Tekla_Australia_23_December_2025.pdf

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