Stewart v Good Shepherd
Victoria CA · Aug 29, 2025
- Jurisdiction
- international
- Court
- Victoria CA
- Record ID
- stewart-v-good-shepherd-2025-08-29
- Observed outcome
- The application for leave to appeal was dismissed, and the applicant was ordered to pay the costs of the respondents.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Victoria Court of Appeal identified that a self-represented litigant submitted fabricated case law citations and misapplied real authorities in written submissions. The judge noted the possibility of AI usage, explicitly stating that the applicant is responsible for the accuracy of filed documents and that the inclusion of 'phantom authorities' was unhelpful to the applicant's case.
The judge reasoned that the applicant is responsible for the accuracy of all filed documents regardless of the drafting method. The court found that the inclusion of fabricated authorities and misapplied citations wasted time and effort, and did not assist the applicant's legal position.
Victoria CA calls AI citations 'phantom authorities'; flag any unverifiable cite to opposing pro-se litigants immediately.
Failure modes and consequences
- Fabricated Case Law
- Misrepresented Authority
- Pro Se
- Fake Citations
- Misrepresented Authority
- Contract
- AI attribution
- Reported
- Recorded tool
- Artificial Intelligence (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Application for leave to appeal from a judgment of the Trial Division of the Supreme Court of Victoria, determined on the papers.
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 judge noted the applicant may have used 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
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.