What was hallucinated

Fabricated: Case Law | Respondent's written argument cited non-existent case law generated by AI; the Court labeled these 'hallucinations' and imposed $200 costs, noting some but not all accusations by the claimant were correct.

Details

In the case of J.R.V. v. N.L.V., the respondent, appearing in person, used a generative AI tool to prepare parts of her written argument. This resulted in the inclusion of citations to non-existent cases, known as 'hallucinations.' The claimant sought costs due to the need to research and respond to these false citations. The court acknowledged the issue but noted that the respondent was not represented by counsel and was unaware of the AI's capability to generate false citations. Moreover, the claimant was wrong as to the alleged non-existence of some citations. The court ordered the respondent to pay $200 in costs to the claimant.

Sanction teardown · SC British Columbia, Canada · 2025-06-19

J.R.V. v. N.L.V.

What happened

In SC British Columbia, 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)

Respondent's written argument cited non-existent case law generated by AI; the Court labeled these 'hallucinations' and imposed $200 costs, noting some but not all accusations by the claimant were correct.

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

Costs to the claimant in the amount of $200. (monetary penalty: 200 CAD.)

Additional detail

In the case of J.R.V. v. N.L.V., the respondent, appearing in person, used a generative AI tool to prepare parts of her written argument. This resulted in the inclusion of citations to non-existent cases, known as 'hallucinations.' The claimant sought costs due to the need to research and respond to these false citations. The court acknowledged the issue but noted that the respondent was not represented by counsel and was unaware of the AI's capability to generate false citations. Moreover, the claimant was wrong as to the alleged non-existence of some citations. The court ordered the respondent to pay $200 in costs to the claimant.

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/570/J.R.V._v._N.L.V._Canada_19_June_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).