{"meta":{"exportedAt":"2026-10-23T17:38:17.488Z","formatVersion":2,"selection":{"q":"hallucination","system":"","harm":"","context":"","country":"","role":"","relation":"contextual","evidence":"","year":"","response":"regulatory","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":4,"coverage":{"cases":4,"countries":3,"languages":1,"unknownLocation":0,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":4,"minors":0,"coreRelations":2,"contextualRelations":4,"mixedRelations":2,"unknownRelations":0,"relationPending":0,"relationUnknown":0},"countingNote":"Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.","affectedCountNote":"Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.","source":"AI incidents","publisher":"NOPE","url":"https://nope.net/incidents","license":"CC BY 4.0"},"incidents":[{"id":"2026-arizona-appeals-court-strikes-self-represented-appellants-ai-hallucinated-citations-orders-fees-sanction","caseFacts":{"claims":[{"id":"c1","status":"reported","evidence":[{"locator":"In his opening brief with the Court of Appeals, he made eight citations. The court found that six of them were deficient; two were cases that “simply do not exist.”","relation":"supports","source_id":"s1"}],"assertion":"The self-represented appellant's opening brief made eight citations; the court found six deficient, including two cases that do not exist.","causal_attribution":"The court's findings as reported by the Arizona Mirror."},{"id":"c2","status":"reported","evidence":[{"locator":"readily acknowledged that he relied on generative AI to write his brief; he admitted he did nothing to independently verify the citations","relation":"supports","source_id":"s1"}],"assertion":"In a written explanation and at a hearing on the false citations he acknowledged relying on generative AI to write the brief and admitted doing nothing to verify the citations.","causal_attribution":"The appellant's own acknowledgement, recorded in the opinion and reported by the Arizona Mirror."},{"id":"c3","status":"reported","evidence":[{"locator":"Accordingly, citing a hallucinated case in a legal filing is sanctionable conduct; traceable to dealing with the fake citations; appeal was also rejected because there were no supportive legal authorities for his claims once the inaccurate and false citations were stricken","relation":"supports","source_id":"s1"}],"assertion":"The court held that citing a hallucinated case is sanctionable regardless of intent, ordered him to pay the portion of the other party's attorney's fees traceable to the fake citations, and rejected the appeal because no supportive authority remained once the citations were struck.","causal_attribution":"The court's ruling as reported."},{"id":"c4","status":"reported","evidence":[{"locator":"The three-judge panel noted that court rules allow for more severe sanctions, including contempt charges and monetary fines.; isn’t a trained legal professional, it opted to narrowly sanction him","relation":"supports","source_id":"s1"}],"assertion":"The court chose this narrow sanction over contempt or fines because he said he did not intend to deceive and is not a trained legal professional.","causal_attribution":"The court's reasoning as reported."}],"effects":[{"label":"brief citations struck, appeal rejected and fee sanction ordered","claim_id":"c3","direction":"negative"}],"sources":[{"id":"s1","url":"https://kiowacountypress.net/content/arizona-court-appeals-citing-fake-ai-generated-cases-can-get-you-sanctioned-no-matter-your","kind":"news","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-18 (HTTP 200); no translation was needed. Republication of the Arizona Mirror (States Newsroom) report.","independence_group":"arizona-mirror-report-jul-2026"}],"version":1,"ai_roles":["own_use"],"contexts":["justice"],"unknowns":["Which generative AI tool the appellant used.","The amount of the fee award, which depended on the other party's documentation."],"geography":{"basis":"The brief was filed in, and the sanction imposed by, the Arizona Court of Appeals in a Maricopa County probate appeal. Residence is not used.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"Published on the Arizona Mirror's report of the Court of Appeals opinion of 15 July 2026: a self-represented appellant acknowledged relying on generative AI to write a brief that cited nonexistent cases, and the court struck the citations, rejected the appeal and ordered him to pay the fees they caused. The parties are private persons and are not named.","reviewed_on":"2026-10-18"},"ai_involvement":{"basis":"The appellant acknowledged in a written explanation and at a hearing on the false citations that he relied on generative AI to write his opening brief, which the court found cited two nonexistent cases and misstated others; the AI-generated text reached him (communicated_with), and the court read the fabricated citations, struck them, rejected the appeal for want of authority and imposed a fee sanction for them (informed_decision_about). The tool is not named.","status":"supported"},"person_relations":["communicated_with","informed_decision_about"]},"name":"Arizona appeals court strikes a self-represented appellant's AI-hallucinated citations, rejects his probate appeal and orders him to pay fees as a sanction","summary":"In a published opinion of July 2026, the Arizona Court of Appeals found that a self-represented appellant's opening brief in a probate dispute contained eight citations, six of them deficient, including two cases that do not exist. In a written explanation and at a hearing on the false citations he acknowledged relying on generative AI to write the brief and said he did nothing to verify the citations. The court struck the inaccurate and false citations, rejected the appeal because no supportive authority remained, held that citing a hallucinated case is sanctionable whether or not it is intended, and ordered him to pay the share of the other party's attorney's fees traceable to the fake citations. Because he said he did not intend to deceive and is not legally trained, the court chose this narrow sanction over contempt or fines. It described the opinion as the first published Arizona ruling on generative AI hallucinations in filings.","incidentDate":"2026-07-15","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"single_interaction","reportedDate":"2026-07-19","aiSystem":"Generative AI, not identified in the report, that the appellant said he relied on to write his opening brief, which cited two nonexistent cases and misstated others","aiProduct":"Unidentified AI drafting tool","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","financial_loss"],"harmOutcomeSummary":"According to the court, the appellant's AI-drafted brief cited nonexistent cases; the citations were struck, the appeal was rejected and he was ordered to pay the share of the other party's attorney's fees caused by the fake citations.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"One person: the self-represented appellant who used generative AI and was sanctioned.","victimAgeRange":"adult","jurisdiction":"US-AZ","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://kiowacountypress.net/content/arizona-court-appeals-citing-fake-ai-generated-cases-can-get-you-sanctioned-no-matter-your","primarySourceLabel":"Arizona Mirror (States Newsroom), republished by Kiowa County Press, July 2026: Arizona Court of Appeals on sanctions for fake AI-generated cases","firstPublishedAt":"2026-10-18T03:14:48.762612+00:00","updatedAt":"2026-10-18T03:14:48.762612+00:00","scopeVersion":"facts-v3","tags":["hallucinated-citations","self-represented-litigant","appeal","sanction","attorney-fees","arizona"]},{"id":"2026-alabama-supreme-court-dismisses-family-trust-appeal-over-lawyer-ai-hallucinated-citations","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'filed briefs in this appeal that contain numerous invalid, inaccurate, and/or irrelevant citations to legal authorities'; 'They appear to be artificial-intelligence (\"AI\") \"hallucinations,\" i.e., fake authorities created by an AI system'; 'Most of the legal authorities in the briefs are misquoted or nonexistent'","relation":"supports","source_id":"s1"}],"assertion":"The appellants' lawyer filed briefs whose citations the court found numerous, invalid, inaccurate or irrelevant, most of them misquoted or nonexistent, and which the court said appear to be AI hallucinations.","causal_attribution":"The court's own findings."},{"id":"c2","status":"documented","evidence":[{"locator":"'first use of an AI research tool that summarized commentary not readily available through standard legal databases'","relation":"supports","source_id":"s1"}],"assertion":"In a reply-brief footnote quoted by the court, the lawyer attributed two misquotations to an AI research tool that summarised commentary.","causal_attribution":"The lawyer's statement as quoted in the opinion."},{"id":"c3","status":"documented","evidence":[{"locator":"'Hall admitted that many of the legal authorities in his briefs do not exist and that he improperly used AI to obtain those authorities'; 'Hall also informed the Court that he had self-reported his actions to the Alabama State Bar'","relation":"supports","source_id":"s1"}],"assertion":"At the 4 February 2026 show-cause hearing the lawyer admitted that many authorities in his briefs did not exist and that he had improperly used AI to obtain them, and said he had self-reported to the Alabama State Bar.","causal_attribution":"The court's record of the hearing."},{"id":"c4","status":"documented","evidence":[{"locator":"'Because those briefs are grossly deficient under the Alabama Rules of Appellate Procedure, we dismiss the appeal'; 'the dismissal of this appeal is imposed as a sanction because of the particularly egregious facts before us'","relation":"supports","source_id":"s1"}],"assertion":"The court dismissed the appeal because the briefs were grossly deficient, and said the dismissal was imposed as a sanction because of the particularly egregious facts.","causal_attribution":"Established by the opinion."},{"id":"c5","status":"documented","evidence":[{"locator":"'Hall is hereby ordered to pay attorney fees and costs'; 'in the amount of $17,200'; 'Hall is ordered to pay double costs'; 'We also refer Hall to the Alabama State Bar for potential discipline'","relation":"supports","source_id":"s1"}],"assertion":"The court ordered the lawyer to pay $17,200 in attorney fees and costs and double costs of the appeal, and referred him to the Alabama State Bar for potential discipline.","causal_attribution":"Established by the opinion."},{"id":"c6","status":"documented","evidence":[{"locator":"'SELLERS, Justice (concurring in part and dissenting in part)'; 'I do not agree that dismissal of the appeal is appropriate as a sanction for the conduct of a lawyer'; 'I would affirm the judgment of the Mobile Circuit'; 'MENDHEIM, Justice (concurring in part and dissenting in part)'; 'I concur in the dismissal of this appeal'; 'His representation on appeal was of no benefit to them'","relation":"supports","source_id":"s1"}],"assertion":"Justice Sellers, concurring in part and dissenting in part, disagreed that dismissal was an appropriate sanction for a lawyer's conduct but would have affirmed the trial court's judgment on the merits; Justice Mendheim, who concurred in the dismissal, wrote that the lawyer's representation on appeal was of no benefit to the clients.","causal_attribution":"Two separate opinions in the same record; neither is the court's holding."}],"effects":[{"label":"two appellants' appeal was dismissed as a sanction because their lawyer's briefs relied on AI-obtained authorities that were fake or misquoted","claim_id":"c4","direction":"negative"},{"label":"the lawyer was ordered to pay $17,200 and double costs, barred from filing alone in the court and referred to the state bar","claim_id":"c5","direction":"negative"}],"sources":[{"id":"s1","url":"https://publicportal-api.alappeals.gov/courts/68f021c4-6a44-4735-9a76-5360b2e8af13/cms/case/47683AFC-2F85-469D-8562-9DCA094BB680/docketentrydocuments/D95CDD15-7428-4CC9-8389-3CC27AC88089","kind":"court_record","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-14 from CourtListener's archived copy of this court PDF (storage.courtlistener.com, HTTP 200, text extracted with pdftotext) because the court portal URL returned HTTP 403 to the agent; no translation was needed.","independence_group":"alabama-supreme-court-sc-2025-0106"}],"version":1,"ai_roles":["own_use","others_use"],"contexts":["justice","work","relationships"],"unknowns":["Which AI tool the lawyer used; the opinion names none.","Whether the dismissal changed the clients' substantive position; the trial court's summary judgment stands, the main opinion does not decide the merits, and one justice would have affirmed the judgment.","The outcome of the Alabama State Bar referral."],"geography":{"basis":"The appeal was decided by the Supreme Court of Alabama on appeal from the Mobile Circuit Court. The appellants' residence is not used.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"Published because the Supreme Court of Alabama's opinion establishes that it dismissed two appellants' appeal as a sanction after their lawyer filed briefs built on fabricated authorities that he admitted he had obtained by improperly using AI, and that it sanctioned the lawyer and referred him to the state bar. The opinion was read in full.","reviewed_on":"2026-10-14"},"ai_involvement":{"basis":"The court found the briefs' authorities appeared to be AI hallucinations, the lawyer admitted at the show-cause hearing that he had improperly used AI to obtain authorities that do not exist, and his reply-brief footnote quoted by the court says an AI research tool misattributed quotations. The AI output reached the court through the briefs, and the court dismissed the clients' appeal because those briefs rested on fabricated authorities (informed_decision_about for the clients); the lawyer received the fabricated output from the tool (communicated_with) and was sanctioned.","status":"supported"},"person_relations":["communicated_with","informed_decision_about"]},"name":"Alabama Supreme Court dismisses two siblings' family-trust appeal as a sanction after their lawyer admits using AI that produced fake citations","summary":"On 24 April 2026 the Supreme Court of Alabama dismissed an appeal by two siblings in a family dispute over living trusts because their lawyer, W. Perry Hall, had filed briefs in which most of the legal authorities were misquoted or did not exist. The court said they appeared to be AI hallucinations, and at a show-cause hearing in February 2026 Hall admitted that many authorities did not exist and that he had improperly used AI to obtain them. The court ordered Hall to pay the opposing party's fees and costs of $17,200 and double appeal costs, barred him from filing in the court without a co-signing attorney and referred him to the Alabama State Bar. It said the dismissal was imposed as a sanction because of the particularly egregious facts. One justice, concurring in part and dissenting in part, objected to dismissing the appeal as a sanction for the lawyer's conduct but would have affirmed the judgment against the clients on the merits.","incidentDate":"2026-04-24","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2026-04-24","aiSystem":"An AI research tool that, according to the lawyer's reply-brief footnote quoted by the court, summarised legal commentary and misattributed quotations; the lawyer admitted using AI to obtain authorities that do not exist. No product is named in the opinion","aiProduct":"Unidentified AI research tool","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","professional_harm","financial_loss"],"harmOutcomeSummary":"According to the Supreme Court of Alabama, the siblings' appeal was dismissed as a sanction because their lawyer's briefs relied on authorities that were misquoted or did not exist, which he admitted he had obtained by improperly using AI; the lawyer was ordered to pay $17,200 in fees and costs plus double appeal costs and was referred to the state bar.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":2,"affectedCountStatus":"exact","affectedCountEvidence":"One AI user: the appellate lawyer, sanctioned and referred to the bar. Two other people: the two appellants whose appeal was dismissed. The appellee, whose fees were reimbursed, is not counted.","victimAgeRange":"adult","jurisdiction":"US-AL","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://publicportal-api.alappeals.gov/courts/68f021c4-6a44-4735-9a76-5360b2e8af13/cms/case/47683AFC-2F85-469D-8562-9DCA094BB680/docketentrydocuments/D95CDD15-7428-4CC9-8389-3CC27AC88089","primarySourceLabel":"Supreme Court of Alabama, opinion in SC-2025-0106 (released 24 April 2026)","firstPublishedAt":"2026-10-14T03:11:52.987847+00:00","updatedAt":"2026-10-14T03:11:52.987847+00:00","scopeVersion":"facts-v3","tags":["united-states","alabama","legal-profession","sanction","hallucinated-citations","appeal-dismissed"]},{"id":"2025-uk-upper-tribunal-judicial-review-grounds-false-citations-supervising-solicitor-referred-to-sra","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'lodged judicial review proceedings in the Upper Tribunal'; 'What causes me to make that order are the “authorities” cited at [10], [17], [18], and [32] of the grounds.'; 'and no case with the citation [2010] UKUT 35 (IAC) even exists'","relation":"supports","source_id":"s1"}],"assertion":"Judicial review grounds lodged in the Upper Tribunal on 26 June 2025 cited four authorities that the judge could not find or that carried wrong citations, including one citation that does not exist.","causal_attribution":"Judge's order of 20 August 2025 as set out in the judgment."},{"id":"c2","status":"reported","evidence":[{"locator":"'may have relied on false citations which were generated by AI, as'; 'accepted he had done in this case'","relation":"supports","source_id":"s1"}],"assertion":"The tribunal recorded that the supervising solicitor accepted that the junior fee-earner had relied on false citations generated by AI in this case.","causal_attribution":"The tribunal's record of the solicitor's acceptance (the judgment does not say when or in what words he accepted it); no tool, prompt or output is identified."},{"id":"c3","status":"reported","evidence":[{"locator":"'he relied on an outdated precedent on our system, practitioner blogs and personal notes'; 'we were concerned by the suggestion in the statements made by'; 'that the citation errors might have been caused by an “old precedent from previous cases”'; 'He stated that there was no mechanism by which staff at his firm could use AI.'; 'He said that he had, and that he had deleted it.'; 'was unable to offer a clear answer to that question'","relation":"supports","source_id":"s1"}],"assertion":"The solicitor's written explanation of 26 September 2025 said the fee-earner relied on an outdated precedent, practitioner blogs and personal notes, and the tribunal recorded that signed statements by both men suggested the errors might have been caused by an old precedent. At the hearing the solicitor said staff at the firm had no mechanism to use AI, and said he had found and deleted the precedent but could not say what it was.","causal_attribution":"The solicitor's and the fee-earner's own accounts as recorded in the judgment; contrary evidence on the AI origin. The solicitor could not identify the precedent ([53])."},{"id":"c4","status":"documented","evidence":[{"locator":"'we consider that the inclusion of false citations in the grounds for judicial review and'; 'necessitates a referral to the SRA'; 'It matters not how such citation errors come about.'","relation":"supports","source_id":"s1"}],"assertion":"The tribunal referred the supervising solicitor to the Solicitors Regulation Authority because the grounds included false citations and he had failed to supervise their drafting, and said it does not matter how such citation errors come about.","causal_attribution":"Decision stated in the judgment promulgated on 17 November 2025."},{"id":"c5","status":"documented","evidence":[{"locator":"'has now been amended so as to require a legal representative to confirm by a statement of truth that any authority cited within the form'","relation":"supports","source_id":"s1"}],"assertion":"The judgment states that the Upper Tribunal judicial review claim form has been amended to require a legal representative to confirm by a statement of truth that any cited authority exists, can be located with the citation given and supports the proposition for which it is cited.","causal_attribution":"Statement in the judgment's headnote and conclusions."},{"id":"c6","status":"documented","evidence":[{"locator":"'He refused permission for reasons which we need not set out.'","relation":"supports","source_id":"s1"}],"assertion":"Permission to apply for judicial review was refused on 20 August 2025 for reasons the judgment does not set out.","causal_attribution":"Judgment; the refusal is not connected to the citations."}],"effects":[{"label":"supervising solicitor referred to the SRA over false citations in judicial review grounds drafted by a junior fee-earner","claim_id":"c4","direction":"negative"}],"sources":[{"id":"s1","url":"https://caselaw.nationalarchives.gov.uk/ukut/iac/2026/81","kind":"court_record","access":"read","language":"en","translation_note":"Full judgment text read in English by the research agent (an AI) on Find Case Law (HTTP 200); no translation was involved and no human reviewer read it.","independence_group":"ukut-2026-81-judgment"}],"version":1,"ai_roles":["others_use"],"contexts":["justice","work"],"unknowns":["Which AI tool generated the false citations, and what was asked of it; the judgment records only the solicitor's acceptance.","Whether the junior fee-earner used an AI tool: he did not attend the hearing, and the statements he and the solicitor signed suggested an old precedent as the source of the errors.","What action, if any, the Solicitors Regulation Authority has taken on the referral.","Whether other files the fee-earner worked on contain false citations; the tribunal said it was likely but unestablished."],"geography":{"basis":"Event: the grounds were lodged in the Upper Tribunal (Immigration and Asylum Chamber), the Hamid hearing was held at Field House and the referral is to the Solicitors Regulation Authority (judgment). Court: the Upper Tribunal. The solicitor's residence is not stated.","court_countries":["GB"],"event_countries":["GB"],"affected_person_countries":[]},"publication":{"basis":"Published on the Upper Tribunal's own judgment: false citations in judicial review grounds led the tribunal to refer the supervising solicitor to the SRA, and the tribunal records his acceptance that the junior fee-earner relied on AI-generated citations. The referral is documented; the AI origin is reported and the solicitor's earlier contrary accounts are recorded. The solicitor, the fee-earner and the applicant are private persons and are not named in the public text.","reviewed_on":"2026-10-12"},"ai_involvement":{"basis":"The judgment records that the solicitor accepted that the junior fee-earner had relied on false citations generated by AI in this case ([52]), and the tribunal referred him to the SRA because the grounds included those false citations and he had failed to supervise their drafting ([56]). The false authorities reached the tribunal in the grounds; the judge identified them, ordered the show cause process and the panel acted on them in deciding to refer the solicitor (informed_decision_about). The AI origin rests on that recorded acceptance and on the tribunal's reference to his failure to put checks in place 'to ensure that the use of AI did not mislead the tribunal' ([46]). Against it, his written explanation had named an outdated precedent, practitioner blogs and personal notes, the statements he and the fee-earner signed suggested an old precedent, which he said he had deleted and could not describe ([53]), at the hearing he said staff had no mechanism to use AI, and the tribunal said the source of the errors does not matter to the referral. No tool or output is identified.","status":"reported"},"person_relations":["informed_decision_about"]},"name":"UK Upper Tribunal refers a supervising solicitor to the SRA over false citations in judicial review grounds; tribunal records he accepted they were AI-generated","summary":"Judicial review grounds lodged in the Upper Tribunal (Immigration and Asylum Chamber) on 26 June 2025 by a solicitors' firm cited four authorities that the judge could not find or that carried wrong citations and propositions. The firm's compliance officer, a solicitor whose name was on the claim form, said a junior fee-earner had drafted the grounds under his supervision; his written explanation named an outdated precedent, practitioner blogs and personal notes as the sources. After a Hamid hearing on 5 November 2025, the tribunal recorded that he accepted the fee-earner had relied on false citations generated by AI, and in a judgment promulgated on 17 November 2025 it referred him to the Solicitors Regulation Authority for the false citations and his failure to supervise. The tribunal said it does not matter how such errors come about. It also announced that the Upper Tribunal judicial review claim form now requires a statement of truth that cited authorities exist and support the propositions they are cited for.","incidentDate":"2025-06-26","incidentEndDate":"2025-11-17","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2025-11-17","aiSystem":"Unidentified AI tool that, according to the tribunal's record of the solicitor's acceptance, generated the false citations a junior fee-earner relied on; no tool is named","aiProduct":"Unidentified AI tool","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm"],"harmOutcomeSummary":"The supervising solicitor was put through a show cause order and a Hamid hearing and referred to the Solicitors Regulation Authority for false citations in grounds drafted by a junior fee-earner and for failing to supervise ([2026] UKUT 81 (IAC), promulgated 17 November 2025). The AI origin of the citations rests on the tribunal's record that he accepted it; his written explanation had named other sources.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":0,"otherPeopleHarmedMin":1,"affectedCountStatus":"exact","affectedCountEvidence":"One person: the supervising solicitor referred to the SRA. He is not counted as an AI user, because the judgment records the junior fee-earner's reliance on AI-generated citations. The fee-earner, who had left the firm and did not attend, and the applicant, whose permission refusal the judgment does not connect to the citations, are not counted.","victimAgeRange":"adult","jurisdiction":"GB","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"pending","primarySourceUrl":"https://caselaw.nationalarchives.gov.uk/ukut/iac/2026/81","primarySourceLabel":"Find Case Law, [2026] UKUT 81 (IAC), UK v SSHD (AI hallucinations; supervision; Hamid), promulgated 17 November 2025","firstPublishedAt":"2026-10-12T03:12:31.6959+00:00","updatedAt":"2026-10-12T03:12:31.6959+00:00","scopeVersion":"facts-v3","tags":["ai-hallucination","fabricated-citations","legal","immigration","tribunal","supervision","sra-referral","united-kingdom"]},{"id":"2024-tasmania-parole-board-ai-hallucinated-case-law-media-condition-quashed","caseFacts":{"claims":[{"id":"c1","status":"corroborated","evidence":[{"locator":"In December 2024, the Parole Board of Tasmania added a condition that she not speak \"directly or indirectly with any media outlet to claim (her) alleged innocence and/or wrongful conviction\".","relation":"supports","source_id":"s1"},{"locator":"This was replaced by a new parole condition in May 2025","relation":"supports","source_id":"s1"},{"locator":"The condition was tweaked in 2025 to prevent her from communicating directly or indirectly - including through third parties and written statements - with media about her alleged innocence","relation":"supports","source_id":"s2"},{"locator":"The Supreme Court declared that conditions imposed by the Parole Board of Tasmania in December 2024 and May 2025 were invalid and unlawful.","relation":"supports","source_id":"s3"}],"assertion":"In December 2024 the Parole Board of Tasmania added a parole condition barring the parolee from communicating with media to claim her innocence or wrongful conviction, and a broader condition replaced it in May 2025.","causal_attribution":"Not a causal claim."},{"id":"c2","status":"reported","evidence":[{"locator":"used artificial intelligence to prepare a rationale justifying the parole condition, citing case law that was \"fictitious\" and likely \"AI hallucinations\".","relation":"supports","source_id":"s1"},{"locator":"relied upon by the board in creating the conditions, included erroneous AI information, the court was told.","relation":"supports","source_id":"s2"},{"locator":"\"As we now know, those cases didn't exist,\" he said.","relation":"supports","source_id":"s2"}],"assertion":"Her counsel told the Supreme Court that the board's secretary used artificial intelligence to prepare a rationale document justifying the condition and that the case law it cited did not exist.","causal_attribution":"Counsel's statement in court is reported by ABC and AAP. These accounts do not independently verify the generation history or identify the tool. The document itself was not inspected."},{"id":"c3","status":"reported","evidence":[{"locator":"the Board’s decision-making was affected by a document containing legal authorities that were likely AI-generated hallucinations and did not in fact exist","relation":"supports","source_id":"s3"},{"locator":"Justice Estcourt also found that when the parole board made the decision to impose this condition, it had relied on a document that cited case law that was \"fictitious\" and likely \"AI hallucinations\".","relation":"supports","source_id":"s4"}],"assertion":"The Human Rights Law Centre says the State conceded the board's decision-making was affected by a document containing nonexistent authorities likely generated by AI. ABC's 19 September report says the court found the board had relied on the document when imposing the condition.","causal_attribution":"The State's concession as reported by the applicant's representative, and the ABC's report of the court's finding. The ABC's 15 September report says the judge heard this; its 19 September report says the judge found it. The AI origin is stated as likely."},{"id":"c4","status":"corroborated","evidence":[{"locator":"Today in the Supreme Court in Hobart, Justice Stephen Estcourt ruled the condition was invalid because it denied her procedural fairness, was legally unreasonable, and created uncertainty.","relation":"supports","source_id":"s1"},{"locator":"Justice Stephen Estcourt found the condition was made without procedural fairness, was legally unreasonable and was filled with uncertainty.","relation":"supports","source_id":"s2"}],"assertion":"ABC and AAP report that on 15 September 2026 Justice Stephen Estcourt of the Supreme Court of Tasmania ruled the condition invalid because it denied procedural fairness, was legally unreasonable and created uncertainty.","causal_attribution":"The reported grounds of invalidity are procedural fairness, unreasonableness and uncertainty; the AI document is not reported as a separate ground."},{"id":"c5","status":"corroborated","evidence":[{"locator":"The parole board decided to withdraw the condition in August and did not contest it being set aside on Tuesday.","relation":"supports","source_id":"s2"},{"locator":"Mr Coleridge said the parole board met and withdrew the condition that same month","relation":"supports","source_id":"s1"}],"assertion":"The board withdrew the condition in August 2026 and did not contest it being set aside.","causal_attribution":"Not a causal claim."},{"id":"c6","status":"reported","evidence":[{"locator":"The court heard that in August","relation":"supports","source_id":"s1"},{"locator":"brought to the court's attention that the case law referred to in the document did not exist.","relation":"supports","source_id":"s1"}],"assertion":"Her lawyers raised in August 2026 that the case law in the document did not exist, and the board withdrew the condition that month.","causal_attribution":"Counsel's sequence of events; the board refused to explain the withdrawal."},{"id":"c7","status":"reported","evidence":[{"locator":"For almost two years, the conditions imposed by the Parole Board of Tasmania prevented Ms Neill-Fraser from speaking publicly about her claimed innocence","relation":"supports","source_id":"s3"},{"locator":"she had been unable to speak publicly after Tasmania's parole board placed a condition on her release in 2024.","relation":"supports","source_id":"s2"},{"locator":"Any breach of parole could result in the remainder of the sentence having to be served","relation":"supports","source_id":"s6"}],"assertion":"The Human Rights Law Centre says the conditions prevented the parolee from speaking publicly about her claimed innocence for almost two years. The Guardian reports that a parole breach could have meant serving the remaining sentence.","causal_attribution":"The restriction is the effect of the condition; the AI document is one input to the decision that imposed it."},{"id":"c8","status":"reported","evidence":[{"locator":"\"The Parole Board's professional standards will be independently investigated following its use of unverified artificial intelligence in a rationale document which formed part of the materials before the board to impose conditions,\"","relation":"supports","source_id":"s4"}],"assertion":"Tasmania's Attorney-General announced an independent investigation of the Parole Board's professional standards following its use of unverified artificial intelligence in the rationale document.","causal_attribution":"The Attorney-General's statement acknowledges the AI use; it does not quantify its effect on the decision."},{"id":"c9","status":"corroborated","evidence":[{"locator":"\"The Department will undertake a review to determine the extent to which Artificial Intelligence (AI) may have been used to inform past Tasmanian Parole Board decisions,\"","relation":"supports","source_id":"s4"},{"locator":"“The department will undertake a review to determine the extent to which artificial intelligence may have been used to inform past Tasmanian Parole Board decisions,” a justice department spokesperson said.","relation":"supports","source_id":"s5"}],"assertion":"Tasmania's Justice Department said it would review the extent to which AI may have been used to inform past Parole Board decisions.","causal_attribution":"Not a causal claim."}],"effects":[{"label":"a restriction on public speech about claimed innocence from December 2024 until withdrawal in August 2026","claim_id":"c7","direction":"negative"},{"label":"adverse parole decision affected by a rationale document citing likely AI-generated, non-existent case law","claim_id":"c3","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.abc.net.au/news/2026-09-15/susan-neill-fraser-media-ban-parole-board-ai-hallucinations/106302950","kind":"news_report","access":"read","language":"en","translation_note":"Read in English in full from abc.net.au (HTTP 200). Court reporting of the 15 September 2026 hearing; the judgment and orders were not inspected. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"abc-au"},{"id":"s2","url":"https://www.canberratimes.com.au/story/9350990/murderers-gag-order-lifted-after-troubling-ai-error/","kind":"news_report","access":"read","language":"en","translation_note":"Read in English in full from canberratimes.com.au (HTTP 200); Australian Associated Press copy of the same hearing, reported independently of the ABC. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"aap"},{"id":"s3","url":"https://www.hrlc.org.au/news/susan-neill-fraser-gag-order-unlawful/","kind":"organisation_statement","access":"read","language":"en","translation_note":"Read in English in full from hrlc.org.au (HTTP 200). Release by the organisation that represented the parolee; its account of the State's concessions is a party-side account. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"hrlc"},{"id":"s4","url":"https://www.abc.net.au/news/2026-09-19/parole-board-ai-use-review-after-neill-fraser-case/107172064","kind":"news_report","access":"read","language":"en","translation_note":"Read in English in full from abc.net.au (HTTP 200). Same outlet as s1, so the same independence group; carries the Attorney-General's and Justice Department's statements. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"abc-au"},{"id":"s5","url":"https://www.theguardian.com/australia-news/2026/sep/19/tasmania-justice-department-review-ai-artificial-intelligence-fake-citation-murderer-parole-decision-ntwnfb","kind":"news_report","access":"read","language":"en","translation_note":"Read in English in full from theguardian.com (HTTP 200); credited to a staff reporter with Australian Associated Press, so grouped with s2. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"aap"},{"id":"s6","url":"https://www.theguardian.com/australia-news/2026/sep/26/sue-neill-fraser-yacht-murder-ai-court-case-media-ban-tasmania-ntwnfb","kind":"news_report","access":"read","language":"en","translation_note":"Read in English in full from theguardian.com (HTTP 200); Guardian Australia feature by its own reporter. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"guardian-au"}],"version":1,"ai_roles":["institutional_use"],"contexts":["justice"],"unknowns":["Which AI tool was used and the extent of its contribution to the rationale. Counsel identified the secretary as its preparer, but the document and generation history were not inspected.","Whether the rationale document informed the December 2024 decision, the May 2025 decision or both.","The text of the judgment or orders, which could not be read (AustLII HTTP 403).","The findings of the independent investigation and of the Justice Department's review of past parole decisions."],"geography":{"basis":"The Parole Board of Tasmania imposed the condition and the Supreme Court of Tasmania in Hobart set it aside (ABC, AAP). The parolee's country of residence is not stated as such in the sources read.","court_countries":["AU"],"event_countries":["AU"],"affected_person_countries":[]},"publication":{"basis":"This is a concrete restriction of a person's speech through a human parole-board decision. Court reporting and the representative's account describe likely AI-generated false authorities used as an input to that decision. The relation is informed_decision_about and does not require the AI text to mention the parolee. The AI origin remains qualified, and the document's precise role in each of the two successive conditions is unknown. The court's reported grounds concern procedural fairness, unreasonableness and uncertainty.","reviewed_on":"2026-10-06"},"ai_involvement":{"basis":"The Human Rights Law Centre reports the State's concession that the board's decision-making was affected by a rationale document containing nonexistent authorities likely generated by AI. ABC and AAP court reports describe the document's use in imposing the media condition, and the Attorney-General's statement reported by ABC acknowledges unverified AI in material used by the board. These sources connect the AI-supplied legal material to a human decision restricting the parolee's speech. The relation is informed_decision_about. The sources do not establish that AI made claims about the parolee herself, wrote the whole rationale or made the final parole decision. The judgment and the rationale document have not been inspected.","status":"supported"},"person_relations":["informed_decision_about"]},"name":"Tasmania parole media ban quashed after state conceded reliance on likely AI-hallucinated case law","summary":"In December 2024 the Parole Board of Tasmania added a condition to the parole of Susan Neill-Fraser, released in 2022 after serving 13 years for murder and who maintains her innocence, barring her from communicating with media to claim innocence or wrongful conviction; a broader condition replaced it in May 2025. On 15 September 2026 the Supreme Court of Tasmania declared the conditions invalid. Her counsel told the court that the board's secretary had used artificial intelligence to prepare a rationale document justifying the condition and that it cited case law that did not exist. The Human Rights Law Centre, which represented her, says the State conceded that the board's decision-making was affected by a document containing legal authorities that were likely AI-generated hallucinations, and the ABC reports the court found the board relied on that document. The board had withdrawn the condition in August 2026. Tasmania's Attorney-General announced an independent investigation of the board's professional standards over its use of unverified AI, and the Justice Department announced a review of AI use in past parole decisions.","incidentDate":"2024-12-01","incidentEndDate":"2026-09-15","incidentKind":"bounded_series","incidentDatePrecision":"month","exposurePattern":"unknown","reportedDate":"2026-09-15","aiSystem":"An unidentified artificial-intelligence tool that, according to counsel and the Attorney-General, was used to prepare a Parole Board rationale document citing case law that did not exist","aiProduct":"Unidentified AI writing tool","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","loss_of_autonomy"],"harmOutcomeSummary":"The conditions restricted a parolee's public speech from December 2024 until their withdrawal in August 2026. They were declared invalid in September. The Human Rights Law Centre says the State conceded the board's decision-making had been affected by nonexistent legal authorities likely generated by AI. The judgment was not directly inspected, and the sources do not establish whether that document informed the original condition, the replacement or both.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":0,"otherPeopleHarmedMin":1,"affectedCountStatus":"exact","affectedCountEvidence":"One parolee is counted for the reported restriction of her speech. The reviewed sources describe no other identified person harmed by AI use in a parole decision; an announced review of past decisions does not establish additional victims.","victimAgeRange":"elderly","jurisdiction":"AU","platformType":"other","outcomeType":"investigation_opened","outcomeStatus":"ongoing","primarySourceUrl":"https://www.abc.net.au/news/2026-09-15/susan-neill-fraser-media-ban-parole-board-ai-hallucinations/106302950","primarySourceLabel":"ABC News, 15 September 2026: AI hallucinations in parole board submission scuttle media ban on Susan Neill-Fraser","firstPublishedAt":"2026-10-06T04:48:51.9027+00:00","updatedAt":"2026-10-06T04:48:51.9027+00:00","scopeVersion":"facts-v3","tags":["parole","hallucinated-case-law","freedom-of-speech","judicial-review","government-ai-use"]}]}