What was hallucinated

Fabricated: Case Law | Wang cited 'Royal Bank v. Humaira, 2019 ONCA 667' which the court could not locate on CanLII; court concluded it was a non-existent authority likely generated by AI. || Fabricated: Case Law | Wang cited 'Royal Bank v. Rehmani, 2017 ONCA 615' which the court could not verify and found the neutral citation did not match the stated style of cause. || Fabricated: Case Law | Wang cited 'Royal Bank v. St-Onge, 2001 SKCA 117' but the court was unable to locate that style of cause and concluded it was erroneous. || Fabricated: Case Law | Wang cited 'Re H.Y. Louie Co. Ltd., 2001 BCSC 556' for contingent guarantee principles but the court could not verify the citation on CanLII and found it inconsistent with the authorities it purported to rely on.

Sanction teardown · Ontario SCJ, Canada · 2025-12-01

Wang, Fengxi (Re)

What happened

In Ontario SCJ, 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)

Wang cited 'Royal Bank v. Humaira, 2019 ONCA 667' which the court could not locate on CanLII; court concluded it was a non-existent authority likely generated by AI.
Fabricated (Case Law)

Wang cited 'Royal Bank v. Rehmani, 2017 ONCA 615' which the court could not verify and found the neutral citation did not match the stated style of cause.
Fabricated (Case Law)

Wang cited 'Royal Bank v. St-Onge, 2001 SKCA 117' but the court was unable to locate that style of cause and concluded it was erroneous.
Fabricated (Case Law)

Wang cited 'Re H.Y. Louie Co. Ltd., 2001 BCSC 556' for contingent guarantee principles but the court could not verify the citation on CanLII and found it inconsistent with the authorities it purported to rely on.

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

Admonishment

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/1744/Wang-Fengxi-Re-2025-ONSC-6707.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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