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AustraliaProfessional services2024 – ongoing

Massar Briggs Law

AI-assisted citation research for native title proceedings

Massar Briggs Law was ordered to pay costs after false citations entered court documents

StoppedRegulator, audit or court

Problem

A junior solicitor prepared citations while working remotely without access to the underlying documents held by the firm.

Approach

The solicitor said she used Google Scholar results to prepare footnotes, then reused some citations in another filing. The court considered generative AI a likely source of the false references, although the precise mechanism remained uncertain. The principal could not establish that anyone had checked the citations.

Results

No published figures

Takeaway

The firm incurred an indemnity costs order because unchecked references caused other parties additional work and delay. The court identified inadequate supervision and verification as central failures.

Categories

Business function
Finance, risk and legal
Innovation type
Process innovation
AI technology
Generative AI
Evidence
Regulator, audit or court

Sources

  1. Murray on behalf of the Wamba Wemba Native Title Claim Group v State of Victoria [2025] FCA 731
    Federal Court of Australia2 Jul 2025Regulator, audit or court document

Source summaries

[1]Federal Court of Australia2 Jul 2025

The published reasons described false or incorrect references in documents prepared for native title proceedings. The court ordered the firm to pay respondents' related costs on an indemnity basis and treated generative AI involvement as likely.

Full details are in the original sources.

Added 1 Nov 2026 · Updated 1 Nov 2026
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