Jorgensen v JML Rose Pty Ltd (Security for Costs)
Federal Court of Australia · Feb 9, 2026
What happened in this matter?
The Court ordered the appellant to provide $30,000 in security for costs. This decision was based on the appellant's failure to establish that the order would stultify his appeals, his lack of financial candor, and his history of using AI to generate fabricated or misrepresented legal authorities, which unnecessarily increased the respondent's litigation costs.
- Why the court cared
- Fabricated: Case Law | Appellant relied on AI-generated references that included non-existent authorities; JML relied on Wheatley J's prior finding of such AI use to argue increased costs. || Misrepresented: Case Law | Appellant relied on authorities produced or cited that did not support the propositions for which they were cited; Court noted earlier discussion of this issue in JML Rose Pty Ltd v Jorgensen (No 3) [2025] FCA 976.
- Why it matters now
- Repeat AI-citation offenders invite security-for-costs orders; flag prior hallucination history when opposing pro-se litigants.
Why this matter is tracked
The Federal Court of Australia granted an application for security for costs against a pro se appellant, Mr. Jorgensen, in his bankruptcy-related appeals. The Court found that the appellant had failed to provide a statement of affairs and had not been candid regarding his financial position. Crucially, the Court noted the appellant's continued, indiscriminate use of artificial intelligence to generate submissions containing non-existent authorities and misrepresentations, a practice previously identified by Wheatley J. The Court determined that this conduct increased litigation costs and supported the respondent's request for security. Consequently, the Court ordered the appellant to pay $30,000 into court within 28 days, failing which the appeals would be stayed.
Repeat AI-citation offenders invite security-for-costs orders; flag prior hallucination history when opposing pro-se litigants.
Record details
What the record establishes about AI use
The Court refers to the appellant's use of artificial intelligence.
Interlocutory application for security for costs in pending appeals.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Appellant relied on AI-generated references that included non-existent authorities; JML relied on Wheatley J's prior finding of such AI use to argue increased costs.
- Misrepresented: Case Law | Appellant relied on authorities produced or cited that did not support the propositions for which they were cited; Court noted earlier discussion of this issue in JML Rose Pty Ltd v Jorgensen (No 3) [2025] FCA 976.
Questions this record answers
- What happened in Jorgensen v JML Rose Pty Ltd (Security for Costs)?
- The Court ordered the appellant to provide $30,000 in security for costs. This decision was based on the appellant's failure to establish that the order would stultify his appeals, his lack of financial candor, and his history of using AI to generate fabricated or misrepresented legal authorities, which unnecessarily increased the respondent's litigation costs.
- Why does Jorgensen v JML Rose Pty Ltd (Security for Costs) matter for legal AI risk?
- Repeat AI-citation offenders invite security-for-costs orders; flag prior hallucination history when opposing pro-se litigants.
- What does the public record establish about Jorgensen v JML Rose Pty Ltd (Security for Costs)?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Jorgensen v JML Rose Pty Ltd (Security for Costs) summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.