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In Cunningham v healthAlliance NZ Ltd, the Employment Court found that a self-represented litigant’s filings relied on cases that did not exist, which the Court said may have come from generative AI. It reminded the litigant to check AI output against the courts’ guidelines for non-lawyers.
In Cunningham v healthAlliance NZ Ltd [2025] NZEmpC 191, a self-represented litigant’s filings relied on case law the Employment Court could not find and treated as fabricated. The Court said the information may have been provided by generative artificial intelligence. It declined the litigant’s application and formally reminded them to check AI-generated content, referring to the Guidelines for Use of Generative Artificial Intelligence in Courts and Tribunals for non-lawyers.
AI Incidents Aotearoa. (2025). Employment Court found fabricated case law in a litigant’s filings (Cunningham v healthAlliance) (AIA-2026-0017). AI Safety Aotearoa. Retrieved 29 October 2026, from https://aiincidents.nz/register/employment-court-found-fabricated-case-law-in-a-litigants-filings-cunningham-v-healthalliance/
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