JNE24 v Minister for Immigration and Citizenship [2025] FedCFamC2G 1314
·Federal Circuit and Family Court of Australia (Division 2), General Federal Law·AUCosts order
In Australia's Federal Circuit and Family Court, a Western Australian lawyer filed migration submissions citing four fake authorities produced using Claude and 'validated' with Microsoft Copilot, admitting overconfidence in AI. Judge Gerrard ordered him to pay AUD 8,371.30 in personal costs and referred his conduct to the Legal Practice Board of Western Australia.
- Court
- Federal Circuit and Family Court of Australia (Division 2), General Federal Law
- Date
- 2025-08-15
- Who used the AI
- Not recorded
- AI tool
- Claude (research) and Microsoft Copilot (validation)
- Conduct
- In a migration judicial-review matter, a Western Australian lawyer filed submissions citing four cases that did not exist or did not support the propositions advanced. He admitted developing an overconfidence in relying on AI tools and assuming their output was reliable. The proceeding was discontinued and he reimbursed his client in full.
- Outcome
- Costs order
- Penalty
- A$8,371.30
- Regulatory outcome
- Legal Practice Board of Western Australia (LPBWA): The court referred the lawyer's conduct to the Legal Practice Board of Western Australia; no LPBWA disposition has been published — the referral is pending. A personal costs order of AUD 8,371.30 was made against the lawyer, payable to the Minister. (2025-08-15)
- Status
- Verified against listed sources
- Last checked
- 2026-09-11
What was fabricated or misused
- Four cases in the applicant's written submissions either did not exist or did not support the propositions advanced; the court declined to repeat or reproduce the citations.
What the court said
“It demonstrates the inherent dangers associated with practitioners solely relying on the use of artificial intelligence (AI) in the preparation of court documents and the way in which that interacts with a practitioner’s duty to the Court.”
“To be clear, it is not the initial reliance on AI that constitutes the vice in such matters. It is the placing before the Court of false authorities or evidence that constitutes improper conduct and a breach of a legal practitioner’s duty to the Court.”
“Filing submissions with the Court which relied upon hallucinated authorities is some distance below the minimum level of professional conduct owed to their client.”
“It is not sufficient to simply check that the cases cited were not fictitious.”
Timeline
- Administrative Appeals Tribunal made the decision challenged in judicial review.
- Applicant commenced Federal Circuit and Family Court proceedings.
- Applicant filed submissions containing four challenged case citations.
- Court ordered an affidavit explaining how non-existent authorities reached the submissions.
- Lawyer admitted using Claude for research and Copilot to validate submissions.
- Court accepted the applicant's explanation and granted leave to discontinue.
- Court ordered personal costs and referred the lawyer to LPBWA.
Why this case matters
JNE24 extends the Australian migration line after Valu by pairing a regulator referral with a personal costs order against the lawyer, while also recording the client's full reimbursement. The judgment is more exacting than a simple citation-exists check: Judge Gerrard said counsel must read the cases, confirm the propositions, and connect them to the facts. That makes the record useful beside Dayal, where the regulator later changed practice rights, because JNE24 shows the court's front-end response before the regulator acts.
Practice note
Treat AI research as an untrusted lead. Before filing, verify each authority in AustLII or another legal database, read the passages to confirm the stated proposition, and document the check. If a false citation is found, correct the filing with notice to the other side and the court; do not send unilateral correction emails without consent.
Primary sources for this incident
Related regulation records for this incident
- Practice Direction: Use of Artificial Intelligence (PD-AI)FCFCOA · AU
- Generative Artificial Intelligence Practice Note (GPN-AI)Federal Court of Australia · AU
- Practice Note SC Gen 23: Use of Generative Artificial IntelligenceNSW Supreme Court · AU
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “JNE24 v Minister for Immigration and Citizenship [2025] FedCFamC2G 1314”, safelegalai.com/tracker/jne24-v-minister-immigration (accessed 2026-09-16). Data: CC BY 4.0.