Sanction teardown · Alberta LRB, Canada · 2026-06-30
Kay v Association of Academic Staff University of Alberta and University of Alberta (Board of Governors)
What happened
In Alberta LRB, 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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Misrepresented (Case Law)The submission cited Mennes for the principle that the substance of an employer’s action is determined by its practical effects. The Board found that Mennes did not address employer action or its characterization.
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Misrepresented (Case Law)The submission cited Adjei for the principle that section 58.6 has autonomous jurisdiction unaffected by a union grievance or duty of fair representation complaint. The Board found that Adjei involved a duty of fair representation complaint, was not an academic-setting case, and did not mention section 58.6.
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
Warning
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/3020/Kay-v-Association-of-Academic-Staff-University-of-Alberta-2026-ALRB-84.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).