What was hallucinated

Misrepresented: Case Law | Several citations in the memorandum quoted or summarized case law inaccurately; the Court found the summaries and quotations did not correspond to the actual authorities cited. || Misrepresented: Exhibits & Submissions | The memorandum referenced unspecified 'reports' or 'studies' without titles, copies, or formal references, rendering those evidentiary citations unverified and unreliable. || Fabricated: Case Law | Many cited authorities in the applicant's memorandum did not exist; defendant's table identified 45 problematic references out of 62, which the Court characterized as AI-generated fabricated citations and excluded from consideration.

Sanction teardown · Federal Court (Canada), Canada · 2026-07-23

CCDP v. Canada AG & Frantz Saint-Jean

What happened

In Federal Court (Canada), 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:

Misrepresented (Case Law)

Several citations in the memorandum quoted or summarized case law inaccurately; the Court found the summaries and quotations did not correspond to the actual authorities cited.
Misrepresented (Exhibits & Submissions)

The memorandum referenced unspecified 'reports' or 'studies' without titles, copies, or formal references, rendering those evidentiary citations unverified and unreliable.
Fabricated (Case Law)

Many cited authorities in the applicant's memorandum did not exist; defendant's table identified 45 problematic references out of 62, which the Court characterized as AI-generated fabricated citations and excluded from consideration.

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

Adverse Costs Order (monetary penalty: 500 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.

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

Source: https://www.damiencharlotin.com/documents/2710/2026cf993.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checker Back to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49 Sanctions-motion template