Victoria's Supreme Court reprimanded lawyer Seham Rizkallah over AI-fabricated citations
In Re Walker [2025] VSC 714, solicitor Seham Rizkallah of Rizkallah Partners used CourtAid and ChatGPT to prepare opening submissions in a contested probate matter, resulting in four legal authorities being filed that either did not exist or were misrepresented. Justice Steven Moore found her conduct constituted unsatisfactory professional conduct and imposed a formal reprimand, declining to refer the matter to the Victorian Legal Services Commissioner.
AI legal research tools fabricated nonexistent case citations that a lawyer filed without verification, exposing the gap between AI-generated plausibility and legal accuracy.
Key facts
- What
- In Re Walker [2025] VSC 714, solicitor Seham Rizkallah of Rizkallah Partners used CourtAid and ChatGPT to prepare opening submissions in a contested probate matter, resulting in four legal authorities being filed that either did not exist or were misrepresented.
- Incident date
- Nov 24, 2025
- Who
- Rizkallah Partners
- Failure mode
- Hallucination
- AI surface
- Search / RAG
- Severity
- Medium
What happened
Seham Rizkallah, principal of Rizkallah Partners, used CourtAid and ChatGPT to identify case authorities for the defendant's opening submissions in a contested probate matter before the Supreme Court of Victoria. Four authorities cited in those submissions could not be located by the judge's chambers, with at least one being entirely fabricated and another misrepresented. When confronted, Rizkallah could not verify the citations and acknowledged that the AI tool produced a reference she filed without confirmation. Justice Steven Moore found her conduct amounted to unsatisfactory professional conduct, citing her ignorance of the court's AI guidelines and failure to verify AI output, and imposed a formal reprimand.
What broke inside the model
- 01 · TriggerA user asks for a fact, a citation, or a figure.
- 02 · Model stepThe model writes a fluent, confident answer.
- 03 · Control gapNothing ties the claim back to a real source.
- 04 · FailureA fabricated fact ships as if it were verified.
- 05 · ConsequenceThe false claim reaches a customer, a court, or the public.
Confidence holds, and even spikes, as the claim detaches from any source.
CourtAid and ChatGPT generated plausible-sounding legal citations with no basis in real case law, reflecting the well-documented hallucination tendency of large language models. The lawyer failed to verify any AI-generated citations before filing them with the court and was unaware of the Supreme Court of Victoria's published guidelines on responsible AI use in litigation. The AI tools produced fabricated and mischaracterized authorities that the models presented as legitimate precedent.
What it cost
Sources
- Court FilingRe Walker [2025] VSC 714 (24 November 2025)websitedc.s3.amazonaws.com
- PressReprimand for principal lawyer for using AI in estate litigationlawyersweekly.com.au
- PrimaryAI Hallucination Cases Database - Re Walker (Australia)damiencharlotin.com
Cite this entry
https://failureindex.ai/failures/victoria-supreme-court-reprimanded-lawyerAI Failure Index. "Victoria's Supreme Court reprimanded lawyer Seham Rizkallah over AI-fabricated citations" (FI-0134). Realm Labs. https://failureindex.ai/failures/victoria-supreme-court-reprimanded-lawyer (indexed Jun 4, 2026).Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0134. Full dataset at /data.
Note from Realm Labs, the Index steward
How Realm would have caught this
- Prism
- OmniGuard
- AI Detection & Response (AIDR)
A runtime layer that watches the model's internal state can flag the moment a model commits to a claim it has no support for, and hold or reroute the response before it reaches a user. Realm reads those signals in real time rather than grading the transcript after the fact.