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Andrey Ivanov & Hometrade Realty Inc. Brokerage v. Uri Kiselman & Viva Solar Inc. (Costs Endorsement)

Court
ON SCSM
Jurisdiction
Canada
Decided
2026-01-29
AI tool
Implied
Outcome
The court found the submissions contained AI-like hallucinations and ordered the paralegal Ms. Derya Vural to personally pay $2,000 to opposing counsel in trust under Rule 19.06 and s.29 of the Courts of Justice Act.
Monetary penalty
1

What was hallucinated

Fabricated: Case Law | Cited 'Sandler v. Goldstein, 2007 ONCA 153' as authority on commissions; no such case exists at that citation (2007 ONCA 153 is Re DeFilippis). || Misrepresented: Case Law | Cited 'Sutton Group Admiral Realty Inc. v. Taborovska, 2021 ONSC 1747' for proposition about BRA; the court found 2021 ONSC 1747 is Rogers Estate v Rogers and the Taborovska matters exist at different citations (2021 ONSC 2837 and 5054). || Fabricated: Case Law | Cited 'Re/Max Realtron Realty Inc. v. Hogue, 2003 CanLII 52184' as holding requirement of a signed agreement for commission; the cited identifier corresponds to an unrelated case and no matching Re/Max Realtron v Hogue at that citation was found. || Fabricated: Case Law | Cited 'Royal LePage Real Estate Services Ltd. v. 2161792 Ontario Inc., 2020 ONSC 4785' for commission law; 2020 ONSC 4785 is actually Kinsella v. Mills and no case by that Royal LePage name was located at that citation. || Fabricated: Case Law | Cited 'Sutton Group Incentive Realty Inc. v. Klundert, 2014 ONSC 7395' for damages for breach of BRA; no case exists at that citation nor under that name was located. || Fabricated: Case Law | Cited 'Westmerc Commercial Properties Ltd. v. MacDonald, 1998 CanLII 14941' for veil-piercing; the cited identifier corresponds to R. v. Alibhai and no Westmerc v. MacDonald was found at that citation. || Fabricated: Legal Norm | Asserted 'section 13' of the Statute of Frauds, RSO 1990, c. S.19 requires written signed commission agreements; no Section 13 exists in the current Statute and the statutory assertion was incorrect.

Details

The paralegal for Ivanov filed written submissions citing multiple non-existent or mis-cited cases and a non-existent statutory section, conduct the Court identified as having all the hallmarks of AI-generated "hallucinations." The Court gave the paralegal an opportunity to show cause and to provide source material but she failed to do so. Relying on the Chief Justice's AI Practice Direction and applicable Small Claims rules, the Court concluded the conduct was misleading and imposed a $2,000 personal penalty on the paralegal under Rule 19.06 and s.29 of the Courts of Justice Act.

Sanction teardown · ON SCSM, Canada · 2026-01-29

Andrey Ivanov & Hometrade Realty Inc. Brokerage v. Uri Kiselman & Viva Solar Inc. (Costs Endorsement)

What happened

In ON SCSM, Canada, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Cited 'Sandler v. Goldstein, 2007 ONCA 153' as authority on commissions; no such case exists at that citation (2007 ONCA 153 is Re DeFilippis).
  • Misrepresented (Case Law)
    Cited 'Sutton Group Admiral Realty Inc. v. Taborovska, 2021 ONSC 1747' for proposition about BRA; the court found 2021 ONSC 1747 is Rogers Estate v Rogers and the Taborovska matters exist at different citations (2021 ONSC 2837 and 5054).
  • Fabricated (Case Law)
    Cited 'Re/Max Realtron Realty Inc. v. Hogue, 2003 CanLII 52184' as holding requirement of a signed agreement for commission; the cited identifier corresponds to an unrelated case and no matching Re/Max Realtron v Hogue at that citation was found.
  • Fabricated (Case Law)
    Cited 'Royal LePage Real Estate Services Ltd. v. 2161792 Ontario Inc., 2020 ONSC 4785' for commission law; 2020 ONSC 4785 is actually Kinsella v. Mills and no case by that Royal LePage name was located at that citation.
  • Fabricated (Case Law)
    Cited 'Sutton Group Incentive Realty Inc. v. Klundert, 2014 ONSC 7395' for damages for breach of BRA; no case exists at that citation nor under that name was located.
  • Fabricated (Case Law)
    Cited 'Westmerc Commercial Properties Ltd. v. MacDonald, 1998 CanLII 14941' for veil-piercing; the cited identifier corresponds to R. v. Alibhai and no Westmerc v. MacDonald was found at that citation.
  • Fabricated (Legal Norm)
    Asserted 'section 13' of the Statute of Frauds, RSO 1990, c. S.19 requires written signed commission agreements; no Section 13 exists in the current Statute and the statutory assertion was incorrect.

Which AI tool

an unnamed/unconfirmed AI tool. 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

The court found the submissions contained AI-like hallucinations and ordered the paralegal Ms. Derya Vural to personally pay $2,000 to opposing counsel in trust under Rule 19.06 and s.29 of the Courts of Justice Act. (monetary penalty: 1 .)

Additional detail

The paralegal for Ivanov filed written submissions citing multiple non-existent or mis-cited cases and a non-existent statutory section, conduct the Court identified as having all the hallmarks of AI-generated "hallucinations." The Court gave the paralegal an opportunity to show cause and to provide source material but she failed to do so. Relying on the Chief Justice's AI Practice Direction and applicable Small Claims rules, the Court concluded the conduct was misleading and imposed a $2,000 personal penalty on the paralegal under Rule 19.06 and s.29 of the Courts of Justice Act.

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.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/2934/2026canlii87466.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2934/2026canlii87466.pdf

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