What was hallucinated

Fabricated: Legal Norm | The factums referenced statutory provisions that do not exist (fabricated legal norms); court flagged the references as invented. || Fabricated: Exhibits & Submissions | Provided notional hyperlinks to authorities that instead linked to wholly irrelevant documents, creating misleading exhibits/submissions. || Fabricated: Case Law | Factums referenced non-existent case law throughout, citing cases that do not exist; court identified the citations as fabrications. || Misrepresented: Case Law | Genuine cases were miscited and relied on for propositions those cases did not address; court characterised these as misrepresentations of precedent. || False Quotes: Case Law | Quoted text attributed to case law and statutes was fabricated (false quotations); court noted quoted passages were made up.

Sanction teardown · CA Ontario, Canada · 2025-09-23

Stile Carpentry Ltd. v. 2004424 Ontario

What happened

In CA Ontario, 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 (Legal Norm)

The factums referenced statutory provisions that do not exist (fabricated legal norms); court flagged the references as invented.
Fabricated (Exhibits & Submissions)

Provided notional hyperlinks to authorities that instead linked to wholly irrelevant documents, creating misleading exhibits/submissions.
Fabricated (Case Law)

Factums referenced non-existent case law throughout, citing cases that do not exist; court identified the citations as fabrications.
Misrepresented (Case Law)

Genuine cases were miscited and relied on for propositions those cases did not address; court characterised these as misrepresentations of precedent.
False Quotes (Case Law)

Quoted text attributed to case law and statutes was fabricated (false quotations); court noted quoted passages were made up.

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/814/2025onca669.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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