Pasuengos v Minister for Immigration and Citizenship (No 2)
Federal Circuit and Family Court · Feb 3, 2026
What happened in this matter?
The court referred the applicant's legal representatives to the Legal Profession Conduct Commissioner (SA) for disciplinary investigation after they filed submissions containing three non-existent, AI-hallucinated case citations. The court determined that the failure to verify the existence and relevance of these authorities constituted a serious breach of the practitioners' duty to the court.
- Why the court cared
- Fabricated: Case Law | A case cited at para [27] of the applicant's original submissions was non-existent; the court found it was AI-generated and refused to reproduce it. Counsel admitted the citations came from an AI-generated Google summary. || Fabricated: Case Law | A second case cited at para [27] of the applicant's original submissions was non-existent; the court determined it was a hallucinated authority produced by AI and did not rely on it. || Fabricated: Case Law | A third case cited at para [27] of the applicant's original submissions was non-existent; the court treated it as an AI hallucination and the solicitors withdrew reliance on the citation.
- Why it matters now
- Never cite from AI-generated Google summaries; treat any Overview snippet as unverified until confirmed in primary databases.
Why this matter is tracked
In Pasuengos v Minister for Immigration and Citizenship (No 2), the Federal Circuit and Family Court of Australia addressed the filing of submissions containing three hallucinated case citations. The applicant's legal representatives admitted that the citations were generated via a Google AI summary and were not independently verified. The Court emphasized that while using generative AI is not inherently impermissible, practitioners have a non-delegable duty to verify the existence, relevance, and accuracy of all cited authorities. Finding that the submission of false authorities constituted a serious breach of professional duties, the Court referred both the junior solicitor and the principal solicitor to the Legal Profession Conduct Commissioner (SA) for further investigation, while anonymizing their identities in the judgment.
Never cite from AI-generated Google summaries; treat any Overview snippet as unverified until confirmed in primary databases.
Record details
What the record establishes about AI use
Counsel admitted the citations were the product of a Google search and AI summary.
Judgment delivered following a hearing on 22 July 2025 regarding the conduct of the applicant's legal representatives in filing submissions containing hallucinated authorities.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | A case cited at para [27] of the applicant's original submissions was non-existent; the court found it was AI-generated and refused to reproduce it. Counsel admitted the citations came from an AI-generated Google summary.
- Fabricated: Case Law | A second case cited at para [27] of the applicant's original submissions was non-existent; the court determined it was a hallucinated authority produced by AI and did not rely on it.
- Fabricated: Case Law | A third case cited at para [27] of the applicant's original submissions was non-existent; the court treated it as an AI hallucination and the solicitors withdrew reliance on the citation.
Questions this record answers
- What happened in Pasuengos v Minister for Immigration and Citizenship (No 2)?
- The court referred the applicant's legal representatives to the Legal Profession Conduct Commissioner (SA) for disciplinary investigation after they filed submissions containing three non-existent, AI-hallucinated case citations. The court determined that the failure to verify the existence and relevance of these authorities constituted a serious breach of the practitioners' duty to the court.
- Why does Pasuengos v Minister for Immigration and Citizenship (No 2) matter for legal AI risk?
- Never cite from AI-generated Google summaries; treat any Overview snippet as unverified until confirmed in primary databases.
- What does the public record establish about Pasuengos v Minister for Immigration and Citizenship (No 2)?
- 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 Pasuengos v Minister for Immigration and Citizenship (No 2) 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.