LMN v. STC (No. 2)
Employment Court of New Zealand · Mar 17, 2025
- Jurisdiction
- international
- Court
- Employment Court of New Zealand
- Record ID
- lmn-v-stc-no-2-2025-03-17
- Observed outcome
- The court granted the plaintiff's request for an extension of time to pay security for costs under a revised schedule, declined her request to file further submissions, and ordered her to pay $500 in costs to the defendant.
- Known monetary consequence
- NZ$500
Why this matter warrants attention
The Employment Court of New Zealand issued a formal warning to a pro se litigant after she cited a non-existent case in her submissions. The court identified the citation as a hallucination likely resulting from the use of generative AI and reminded the litigant of the necessity to verify all AI-generated information before filing.
The court identified that the cited case 'Fowlie v Stonex (No 2) [2015] NZEmpC 94' does not exist and attributed the error to the plaintiff's reliance on unverified generative AI output.
NZ courts are now issuing express warnings on generative AI reliance even without monetary penalty.
Failure modes and consequences
- Pro Se
- Fake Citations
- Employment
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- NZ$500
- Procedural posture
- Interlocutory judgment on applications to vary a security-for-costs order and for leave to file further submissions.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court explicitly referenced the plaintiff's use of generative artificial intelligence.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all legal citations and authorities, regardless of the research source.
- Review and disseminate the 'Guidelines for Use of Generative Artificial Intelligence in Courts and Tribunals: Non-lawyers' to relevant stakeholders.
- Establish internal controls to ensure that any AI-assisted drafting is subject to human review for factual and legal accuracy.