What was hallucinated

Fabricated: Case Law | Memorandum cited two non-existent Supreme Court judgments generated by AI and attributed legal principles to them; Court found the judgments do not exist. || Fabricated: Case Law | Memorandum cited two non-existent lower court judgments generated by AI and quoted purported holdings from them; Court found the judgments do not exist. || Fabricated: Case Law | Appellant reproduced specific quotations of legal principles attributed to the fabricated decisions; Court determined the quotations were invented along with the decisions. || Fabricated: Case Law | Appellant acknowledged the authorities and quotations were produced by ChatGPT and that some were removed from his book of authorities; Court found he nonetheless filed a memorandum containing fabricated references.

Sanction teardown · CA Québec, Canada · 2026-08-11

A. P. v. S. K.

What happened

In CA Québec, Canada, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Memorandum cited two non-existent Supreme Court judgments generated by AI and attributed legal principles to them; Court found the judgments do not exist.
Fabricated (Case Law)

Memorandum cited two non-existent lower court judgments generated by AI and quoted purported holdings from them; Court found the judgments do not exist.
Fabricated (Case Law)

Appellant reproduced specific quotations of legal principles attributed to the fabricated decisions; Court determined the quotations were invented along with the decisions.
Fabricated (Case Law)

Appellant acknowledged the authorities and quotations were produced by ChatGPT and that some were removed from his book of authorities; Court found he nonetheless filed a memorandum containing fabricated references.

Which AI tool

ChatGPT. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Monetary Sanction (monetary penalty: 1000 CAD.)

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

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Source: https://www.damiencharlotin.com/documents/2830/AP_v._SK_Canada_11_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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