Sanction teardown · Federal PSLREB, Canada · 2025-10-01
Hogan v. Treasury Board
What happened
In Federal PSLREB, 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:
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False Quotes (Legal Norm)Complainant repeatedly quoted an invented version of s.129(6) of the Canada Labour Code to claim entitlement to continued wages; the Board noted the quoted wording is fabricated and irrelevant because no directions were made by the Head.
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Fabricated (Case Law)Complainant cited 'Merriweather v. Canada (Attorney General), 2012 FC 109', which the Board states does not exist.
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Fabricated (Doctrinal Work)Complainant relied on a 'H&S Officer Training Module - Labour Program, 2018 edition' that the Board could not locate and treats as non-existent.
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Outdated Advice (Repealed Law)Complainant relied on ss. 22 and 44 of the (former) FPSLRA to claim broad remedial/interim powers; the Board noted those sections were repealed in 2013 and did not say what the complainant attributed to them.
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Fabricated (Case Law)Complainant cited 'Fanning v. Treasury Board, 2023 FPSLREB 12', which the Board states does not exist.
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Fabricated (Case Law)Complainant cited 'Vancouver v. CUPE, 2006 SCC 27', which the Board states does not exist.
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Fabricated (Case Law)Complainant cited 'Canadian Human Rights Commission v. Canada (AG), 2018 FCA 12', which the Board states does not exist.
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Misrepresented (Case Law)Complainant relied on IWA v. Consolidated-Bathurst Packaging Ltd., [1990] 1 SCR 282 for the proposition that administrative tribunals have authority to grant interim relief; the Board noted the case does not address interim relief and was mischaracterized.
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Misrepresented (Case Law)Complainant relied on Wilson v. Atomic Energy of Canada Ltd., 2016 SCC 29 for the proposition that tribunals can grant interim relief; the Board found this to be a mischaracterization of that decision.
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Misrepresented (Case Law)Complainant claimed White v. Treasury Board (Correctional Service of Canada), 2022 FPSLREB 52 supported interim wage orders; the Board observed that decision did not order interim relief and the complainant misrepresented it.
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
Not specified in source record.
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/1756/Hogan-v.-Treasury-Board-Department-of-Employment.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).