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X.L. v. Z.L. et al

Court
Ontario SCJ
Jurisdiction
Canada
Decided
2025-10-16
AI tool
Implied
Outcome
No reliance on authorities submitted; Monetary Sanction
Monetary penalty
1000 CAD

What was hallucinated

Fabricated: Case Law | Citation to Gowling Lafleur Henderson LLP v. Shorter, 2011 ONSC 5840 could not be located (hyperlink led to an error); court treated it as AI-generated. || Misrepresented: Case Law | Duggan v. Durham Region Law Association (2022 ONCA 216) was cited but hyperlinks directed to a different case and the citation/report could not be relied upon for the proposition advanced. || Misrepresented: Case Law | Indalex Ltd., Re (2013 SCC 6) was cited for an unrelated proposition (pension administration case) and did not support the legal point advanced by the respondents. || Misrepresented: Case Law | Ontario Inc. v. Ranch Heating and Air Conditioning (Barrie) Limited (2012 ONCA 182) was cited for a point about concealing/diverting assets but the case concerns negligence; citation misapplied. || Misrepresented: Case Law | Ontario (Attorney General) v. Trinity Bible Chapel (2023 ONCA 134) was cited for fraudulent conveyance principles though it is a Charter/Covid-regulation case; citation misapplied. || Misrepresented: Case Law | Ms. Shek cited Bank of Montreal v. Wilder for a proposition about fraudulent intent; the hyperlink led to Schuldt v. The Queen and the cited proposition was unsupported. || Misrepresented: Case Law | Reference to Royal Bank of Canada v. North American Life Assurance Co. was hyperlinked to Gordon v. Goertz and did not support the proposition cited by the respondent. || Fabricated: Case Law | Pinto v. BMO Trust Company (2017 ONCA 120) was cited but the case/report could not be located on reporting services; treated as an AI hallucination.

Details

Costs were awarded here.

Sanction teardown · Ontario SCJ, Canada · 2025-10-16

X.L. v. Z.L. et al

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)
    Citation to Gowling Lafleur Henderson LLP v. Shorter, 2011 ONSC 5840 could not be located (hyperlink led to an error); court treated it as AI-generated.
  • Misrepresented (Case Law)
    Duggan v. Durham Region Law Association (2022 ONCA 216) was cited but hyperlinks directed to a different case and the citation/report could not be relied upon for the proposition advanced.
  • Misrepresented (Case Law)
    Indalex Ltd., Re (2013 SCC 6) was cited for an unrelated proposition (pension administration case) and did not support the legal point advanced by the respondents.
  • Misrepresented (Case Law)
    Ontario Inc. v. Ranch Heating and Air Conditioning (Barrie) Limited (2012 ONCA 182) was cited for a point about concealing/diverting assets but the case concerns negligence; citation misapplied.
  • Misrepresented (Case Law)
    Ontario (Attorney General) v. Trinity Bible Chapel (2023 ONCA 134) was cited for fraudulent conveyance principles though it is a Charter/Covid-regulation case; citation misapplied.
  • Misrepresented (Case Law)
    Ms. Shek cited Bank of Montreal v. Wilder for a proposition about fraudulent intent; the hyperlink led to Schuldt v. The Queen and the cited proposition was unsupported.
  • Misrepresented (Case Law)
    Reference to Royal Bank of Canada v. North American Life Assurance Co. was hyperlinked to Gordon v. Goertz and did not support the proposition cited by the respondent.
  • Fabricated (Case Law)
    Pinto v. BMO Trust Company (2017 ONCA 120) was cited but the case/report could not be located on reporting services; treated as an AI hallucination.

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

No reliance on authorities submitted; Monetary Sanction (monetary penalty: 1000 CAD.)

Additional detail

Costs were awarded here.

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/890/2025onsc5880.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/890/2025onsc5880.pdf

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