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Lloyd’s Register Canada v. Munchang Choi

Court
Federal Court of Canada
Jurisdiction
Canada
Decided
2025-07-10
AI tool
Unidentified
Outcome
Motion Record removed from Court file; costs awarded to Applicant
Monetary penalty
500 CAD

What was hallucinated

Misrepresented: Case Law | Respondent misrepresented Fontaine by claiming it supports subpoena discretion; the Court noted the case concerns residential schools appeal motions, not subpoenas. || Fabricated: Case Law | Respondent cited a non-existent case; the Court found “Fontaine v Canada, 2004 FC 1777” does not exist and was apparently AI-generated.

Details

The Respondent, a self-represented litigant, used generative AI tools for drafting and preliminary research, leading to the citation of a non-existent case, 'Fontaine v Canada, 2004 FC 1777', in his Motion Record. The Court found this to be a fabricated citation, and the (allegedly) intended citation pointed to an irrelevant case.The court further pointed out that the Respondent had already been caught fabricating citations in a previous proceeding. Despite acknowledging use of AI, the respondent had also failed to provide the declaration on this point required by the AI Practice Direction. The Court ordered the removal of the Motion Record from the file. Costs of $500 CAD were awarded to the Applicant.In a later order, Respondent was designated as a vexatious litigant and enjoined from filing new cases without leave.

Sanction teardown · Federal Court of Canada, Canada · 2025-07-10

Lloyd’s Register Canada v. Munchang Choi

What happened

In Federal Court of 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)
    Respondent misrepresented Fontaine by claiming it supports subpoena discretion; the Court noted the case concerns residential schools appeal motions, not subpoenas.
  • Fabricated (Case Law)
    Respondent cited a non-existent case; the Court found “Fontaine v Canada, 2004 FC 1777” does not exist and was apparently AI-generated.

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

Motion Record removed from Court file; costs awarded to Applicant (monetary penalty: 500 CAD.)

Additional detail

The Respondent, a self-represented litigant, used generative AI tools for drafting and preliminary research, leading to the citation of a non-existent case, 'Fontaine v Canada, 2004 FC 1777', in his Motion Record. The Court found this to be a fabricated citation, and the (allegedly) intended citation pointed to an irrelevant case.The court further pointed out that the Respondent had already been caught fabricating citations in a previous proceeding. Despite acknowledging use of AI, the respondent had also failed to provide the declaration on this point required by the AI Practice Direction. The Court ordered the removal of the Motion Record from the file. Costs of $500 CAD were awarded to the Applicant.In a later order, Respondent was designated as a vexatious litigant and enjoined from filing new cases without leave.

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/584/Lloyds_Register_Canada_Ltd._v._Munchang_Choi_Canada_10_July_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/584/Lloyds_Register_Canada_Ltd._v._Munchang_Choi_Canada_10_July_2025.pdf

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