Skip to main content
NOPE
Medium reported severity Regulatory Action

Ontario: lawyer who relied on ChatGPT-invented case law in a factum was referred for criminal contempt and suspended for six months, legal press reports

An Ontario lawyer relied, at a 1 May 2025 Superior Court hearing in an estate and family-law matter, on a factum citing cases that do not exist or do not support the propositions cited. The judge ordered her to show cause why she should not be cited for contempt, then withdrew the order on 20 May 2025 after she said her staff had used ChatGPT without her knowledge. On 30 September 2025 she told the court that she alone had prepared the factum with ChatGPT and that her earlier account was untrue; the court referred the matter to Ontario’s Attorney General for criminal contempt proceedings in December 2025. In July 2026 the Law Society Tribunal suspended her licence for six months, finding she relied on AI-generated non-existent case law and lied about it. The account comes from legal-press and law-firm reports of the decisions; the criminal contempt case was still ongoing at the last report read.

AI system
ChatGPT
Occurred
1 May 2025
Reported
13 May 2025
Event location
Canada
What the AI did
Communicated with the person
Reported harm
Professional HarmLegal HarmReputational Harm
Whose AI use
Their own AI use
Setting
Justice · Work
Evidence
AI involvement reported · Causal attribution supported · 7 sources, 2 underlying accounts
6 claims: 6 reported. 4 open questions
People reported harmed
1 person

AI system as recorded: ChatGPT, which the lawyer admitted using to prepare the factum and which the Law Society Tribunal found generated the non-existent or irrelevant case law

What Happened

According to Canadian Lawyer’s report of the first endorsement, the applicant’s counsel presented a motion on 1 May 2025 in an application arising from a testator’s death, and during oral submissions delivered a factum and cited cases in support. When the judge could not locate the cases, the judge asked whether AI such as ChatGPT had supported the factum’s preparation; the lawyer said she would have to ask her clerk and could not supply correct citations or copies. Later accounts give her answer differently: Law360 Canada says she denied in open court that she had used ChatGPT, and the tribunal reasons, as reported by Law Times, say she told the judge she had not. Reviewing the factum after the hearing, the judge found further errors, including another non-existent case and a case that stood for the opposite proposition. He wrote that the factum may have been created by AI and not checked, and ordered the lawyer to show cause why she should not be cited for contempt. At a scheduling conference on 16 May 2025 she apologised; in a decision released on 20 May 2025 the court found it unnecessary to continue, after she told it her staff had used ChatGPT without her knowledge and undertook at least six hours of continuing professional education. On 30 September 2025 she wrote to the court that there was no student and that she alone had prepared the factum with ChatGPT. On 4 December 2025 the court, describing the new disclosure as raising issues of deception of the court in a contempt proceeding, referred the matter to the Attorney General of Ontario for criminal contempt proceedings and appointed an amicus curiae. On 16 July 2026 the Law Society Tribunal suspended her licence for six months from 17 July and ordered her to pay $10,000, finding that she relied on a factum containing only non-existent or irrelevant AI-generated case law and later lied about not using the tool. Its reasons, as reported by Law Times on 21 July 2026, say using AI is not misconduct in itself, that she failed to verify the factum and so failed to serve her client, that her repeated lies to the court and the Law Society were the more serious failures, and that her conduct was out of character after a 30-year career without discipline. The criminal contempt case was reported as ongoing.

Reported harm

According to legal-press reports of the court and tribunal decisions, the lawyer faced a contempt show-cause order and a referral for criminal contempt, and the Law Society Tribunal suspended her licence for six months and ordered her to pay $10,000 to the Law Society of Ontario; the court noted she had suffered a public shaming near the end of an unblemished career.

How Harm Occurred

ChatGPT produced citations to cases that do not exist or do not support the propositions cited; the lawyer filed and argued them without checking. The court’s contempt proceedings and the regulator’s suspension responded to that reliance and, more heavily, to her later false account of who used the tool.

Outcome

Ongoing

The Ontario Superior Court of Justice ordered the lawyer to show cause for contempt (May 2025), found it unnecessary to continue the contempt proceedings after her first explanation and apology (20 May 2025), and after her September 2025 admission referred the matter to the Attorney General for criminal contempt proceedings and appointed an amicus curiae (4 December 2025). The Law Society Tribunal suspended her licence for six months from 17 July 2026 and ordered her to pay $10,000 to the Law Society of Ontario; the lawyer and the Law Society had jointly agreed that a six-month suspension was appropriate. The criminal contempt case was reported as ongoing on 21 July 2026.

What remains unknown

  • The outcome of the criminal contempt proceeding referred to the Attorney General; the latest source read (21 July 2026) says it remained ongoing.
  • Whether the client suffered any concrete consequence in the estate application; the tribunal found the lawyer failed to serve her client but no source read describes an effect on the case.
  • Which ChatGPT version was used and what prompts produced the citations.
  • The court endorsements and the tribunal order and reasons were not read directly (CanLII returned 403); all claims rest on legal-press and law-firm accounts of them.

What the evidence supports

AI involvement: reported. The lawyer told the court in September 2025 that she alone prepared the factum using ChatGPT, and the Law Society Tribunal, as reported by Law Times, found that she relied on a factum containing only non-existent or irrelevant case law generated by an AI tool and that she used ChatGPT to prepare it. ChatGPT’s output (citations to cases that do not exist or do not support the propositions) reached the lawyer, who filed it and relied on it orally at the 1 May 2025 hearing; the court’s contempt proceedings and the tribunal’s suspension followed from that reliance and from her later false account of it. The tribunal’s main concern was her dishonesty, which is a separate act by the lawyer.

6 claims: 6 reported. What the statuses mean

Reported At a motion hearing on 1 May 2025 in an Ontario Superior Court of Justice estate and family-law application, the applicant’s lawyer relied in writing and orally on a factum citing cases that the judge could not find or that did not support the propositions cited; asked whether AI such as ChatGPT had been used, the lawyer said, according to Canadian Lawyer and LawSites, that she would have to ask her clerk, while Law360 Canada and the tribunal reasons as reported by Law Times say she denied using ChatGPT.

Causal attribution. Account of the court’s first endorsement (2025 ONSC 2766) as relayed by two legal-press outlets, with the lawyer’s answer in court given differently by Law360 Canada and by the tribunal reasons as reported by Law Times; the endorsement itself was not read.

  • canadianlawyermag.com(opens in new tab) supports · English
    'On May 1, the applicant’s counsel presented a motion seeking relief in this application. During oral submissions, she delivered a factum and cited cases to support the applicant’s arguments.'; 'The judge asked the lawyer if AI like ChatGPT supported the preparation of the factum. She said she would have to ask her clerk.'
  • lawnext.com(opens in new tab) supports · English
    'After the hearing, the judge again reviewed the factum and found two more incorrect citations — one to a non-existent case and another to a case that stood for the opposite proposition than that for which it had been cited.'
  • law360.ca(opens in new tab) supports · English
    'When Justice Myers confronted her in open court about whether she had used ChatGPT, she categorically denied it, stating, “I did not.”'
  • lawtimesnews.com(opens in new tab) supports · English
    'whether she had used ChatGPT to write her factum'; 'said she had not.'
Reported The judge found that the factum appeared to have been created by AI and not checked, and ordered the lawyer to show cause why she should not be cited for contempt of court.

Causal attribution. The court’s own statement, as quoted by LawSites and summarised by Cassels.

  • lawnext.com(opens in new tab) supports · English
    'factum may have been created by AI and that before filing the factum and relying on it in court, she might not have checked to make sure the cases were real'; 'the judge ordered the attorney to show cause why she should not be cited for contempt.'
  • cassels.com(opens in new tab) supports · English
    'counsel was ordered to return for a show cause hearing to argue why she should not be cited for contempt of court'
Reported After telling the court that her staff had used ChatGPT to prepare the factum without her knowledge, apologising and undertaking continuing professional education, the lawyer had the show-cause order withdrawn in a decision released on 20 May 2025, which noted that she had suffered a public shaming near the end of an unblemished career.

Causal attribution. The court’s second decision (2025 ONSC 2965) as summarised by Cassels and recited in the tribunal reasons reported by Law Times.

  • cassels.com(opens in new tab) supports · English
    'At an informal scheduling conference on May 16, 2025, counsel was forthright in admitting her error and provided an explanation.'; 'In a written decision released on May 20, 2025, the Court found it unnecessary to continue with contempt proceedings'
  • lawtimesnews.com(opens in new tab) supports · English
    'explaining that her staff had used ChatGPT to prepare the factum without her knowledge. She apologized for the mistake and promised to complete at least six hours of continuing professional education in legal ethics and technology.'; 'suffered a public shaming near the end of an unblemished career,'
Reported On 30 September 2025 the lawyer wrote to the court that she alone had prepared the factum using ChatGPT and that her earlier account blaming staff was untrue; on 4 December 2025 the court referred the matter to the Attorney General of Ontario for criminal contempt proceedings and appointed an amicus curiae.

Causal attribution. The court’s third decision (2025 ONSC 6785) as described by Law360 Canada and WeirFoulds; both relay the same decision.

  • law360.ca(opens in new tab) supports · English
    'admitting the truth: there was no student.'; 'The new disclosure raises issues of deception of the court in a contempt of court proceeding. The procedural context and the quality of the acts are very different.'; 'the court appointed amicus curiae Dean Embry to ensure'
  • weirfoulds.com(opens in new tab) supports · English
    'revealing that she alone prepared the AI-assisted factum, reversing her prior claim that others were involved. The court treated this as a fresh act of potential contempt and referred the matter to the Attorney General.'
Reported On 16 July 2026 the Law Society Tribunal suspended the lawyer’s licence for six months from 17 July and ordered her to pay $10,000 to the Law Society of Ontario, finding that she relied on a factum containing only non-existent or irrelevant case law generated by an AI tool and later lied to the court about not using the tool.

Causal attribution. The tribunal’s order as reported by Law Times; the order itself was not read.

  • lawtimesnews.com(opens in new tab) supports · English
    'will have her license to practise law suspended for six months starting July 17. The tribunal'; 'to pay $10,000 to the Law Society of Ontario'; 'containing only non-existent or irrelevant case law generated by an artificial intelligence tool” and later lying to the court about not using the tool.'
Reported The tribunal’s reasons, as reported, say the lawyer failed to serve her client by using ChatGPT to prepare a factum containing hallucinated citations and arguments, that she had prepared the factum herself with little or no prior experience of ChatGPT, that her repeated lies to the court and the Law Society troubled the tribunal more than the reliance, and that the criminal contempt case remained ongoing.

Causal attribution. The tribunal’s reasons as reported by Law Times; the reasons themselves were not read.

  • lawtimesnews.com(opens in new tab) supports · English
    'the lawyer failed to serve her client in a family law matter by using ChatGPT to prepare a factum containing AI-hallucinated case citations and arguments.'; 'Later, she admitted that she had prepared the factum herself and did not know hallucinations existed until Myers confronted her about her submissions.'; 'we are extremely troubled by the lawyer’s subsequent repeated lies to the court and to the law society'; 'had little to no prior experience with ChatGPT'; 'That case remains ongoing.'

Sources

7 sources inspected, from 2 underlying accounts. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

Read in full in English by the research agent (an AI) on 2026-10-12; no translation was involved and no human reviewer read it. Canadian Lawyer, 13 May 2025, reporting the first endorsement (2025 ONSC 2766); HTTP 200. The endorsement itself (CanLII) returned 403 live and from the Internet Archive. Applies to s1.

Read in full in English by the research agent (an AI) on 2026-10-12; no translation was involved and no human reviewer read it. LawSites (LawNext), 14 May 2025, summarising the same endorsement; HTTP 200. Applies to s2.

Read in full in English by the research agent (an AI) on 2026-10-12; no translation was involved and no human reviewer read it. Cassels law-firm commentary, 23 May 2025, summarising 2025 ONSC 2766 and 2025 ONSC 2965; HTTP 200. Applies to s3.

Read in full in English by the research agent (an AI) on 2026-10-12; no translation was involved and no human reviewer read it. Law360 Canada analysis, 8 Dec 2025, describing 2025 ONSC 6785 and quoting it; HTTP 200 (full text served). Applies to s4.

Read in full in English by the research agent (an AI) on 2026-10-12; no translation was involved and no human reviewer read it. WeirFoulds law-firm article PDF, 23 Dec 2025, on 2025 ONSC 6785; HTTP 200, text extracted with pdftotext. Applies to s5.

Read in full in English by the research agent (an AI) on 2026-10-12; no translation was involved and no human reviewer read it. Law Times, 16 Jul 2026, on the Law Society Tribunal order; HTTP 200. Applies to s6.

Read in full in English by the research agent (an AI) on 2026-10-12; no translation was involved and no human reviewer read it. Law Times, 21 Jul 2026, on the tribunal reasons; HTTP 200. The tribunal order and reasons themselves were not read. Applies to s7.

Event countries: Canada. Affected-person countries: Canada. Court countries: Canada.

The factum was filed and argued at a hearing of the Ontario Superior Court of Justice, and the lawyer is described as a Toronto lawyer licensed by the Law Society of Ontario, whose tribunal suspended her.

Reviewed for publication 2026-10-12: Legal-press and law-firm accounts of three Ontario Superior Court decisions and a Law Society Tribunal order describe a lawyer who relied on ChatGPT-generated nonexistent case law in a factum, was ordered to show cause for contempt, later admitted she alone had used ChatGPT and had misled the court, was referred for criminal contempt and was suspended for six months.

People described

One Ontario sole-practitioner lawyer with a 30-year career, counsel for an applicant in an estate and family-law matter (not named here)

People reported harmed in this case

1 person

1 AI participant · 0 other people harmed

One person, the lawyer who used ChatGPT, is reported to have suffered the contempt proceedings and the suspension. The tribunal found she failed to serve her client, but no source read describes a concrete consequence for the client, who is not counted.

Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.

Tags

#hallucinated_citations#courts#lawyer_sanction#contempt_of_court#professional_discipline#canada#ontario

Cite this case

Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.

APA

NOPE. (2026). Ontario: lawyer who relied on ChatGPT-invented case law in a factum was referred for criminal contempt and suspended for six months, legal press reports. AI incidents. https://nope.net/incidents/2025-ontario-lawyer-chatgpt-factum-invented-cases-contempt-referral-licence-suspension

BibTeX

@misc{2025_ontario_lawyer_chatgpt_factum_invented_cases_contempt_referral_licence_suspension,
  title = {Ontario: lawyer who relied on ChatGPT-invented case law in a factum was referred for criminal contempt and suspended for six months, legal press reports},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2025-ontario-lawyer-chatgpt-factum-invented-cases-contempt-referral-licence-suspension}
}

Related cases

Medium ChatGPT

Saginaw, Michigan: a credit union CEO used ChatGPT to put herself and family members in 'Lake America' sweatshirts in a photo taken before a trip to Halifax; after her sister reposted it publicly without its AI label she says she received death threats and the family came home early, and on 23 September 2026 the credit union said she was no longer employed

The chief executive of Family First Credit Union in Saginaw, Michigan, told WJRT (ABC12) that before boarding a flight to Halifax, Nova Scotia, on 11 September 2026 she and family members took a photo and put it through ChatGPT to show them wearing 'Lake America' sweatshirts, a joke about the US president's order renaming Lake Ontario. She posted it to her private Facebook page with a marker saying it contained AI content; her sister reposted it publicly without the marker while they were in Halifax, and it spread in Canada as if the family had worn the shirts. The backlash concerned the image's political message; she said she would understand the anger of anyone in Halifax who thought the family had walked in wearing those sweatshirts. She said she was getting death threats and the family returned early; by 16 September she was back in the US. She called the post poor judgment, said she would not use AI again and that AI 'can make people think something's real that's not'. On 23 September the credit union said she was no longer an employee, effective immediately; it has not said whether she resigned or was dismissed, or why.

Medium Unidentified AI drafting tool

Former federal prosecutor in North Carolina publicly reprimanded after admitting that a brief with fabricated quotations was drafted with AI; he lost his post

In December 2025 an Assistant U.S. Attorney in the Eastern District of North Carolina filed a response brief for the Department of Defense in a self-represented veteran's lawsuit over health-insurance coverage. The plaintiff identified fabricated quotations and misdescribed case holdings in it. The attorney first attributed the errors to an unfinalized draft filed by mistake. On 2 March 2026 Magistrate Judge Robert T. Numbers II ordered him to show cause why he should not be sanctioned. At the 10 March hearing the attorney, Rudy Renfer, said under oath that he had accidentally overwritten his draft, panicked and used artificial intelligence to draft the brief, and had not verified the cases it cited; he said he had resigned after 17 years in the office, and Courthouse News reported he was terminated the next day. On 28 April 2026 the court issued a public reprimand instead of a fine, writing that his reputation was in tatters and that his job loss already exceeded the usual fines.

Medium ChatGPT

New Mexico Supreme Court fines attorney Stephen Aarons $5,000 and removes him from a murder appeal over ChatGPT-fabricated testimony

Santa Fe defense attorney Stephen Aarons used ChatGPT (OpenAI's o3) on a Rev.com transcript and the record to draft briefing in the murder appeal of Oscar Renee Sandoval; the brief contained fabricated witnesses and testimony (including police officers 'Michelle Amarillo' and 'Sanchez' and invented testimony attributed to real people) and misdescribed real precedents. After a 21 August 2026 show-cause hearing at which Aarons admitted he had not verified the output, the New Mexico Supreme Court's written order of 9 September 2026 held him in direct contempt, fined him $5,000 payable to the State Bar Client Protection Fund within 30 days, removed him from the case, barred him from appearing before the court pending a disciplinary-board referral, struck the filed briefs and reassigned the appeal to the public defender.

High Unidentified AI tool

SDT strikes solicitor Abhishek Kumar off the Register of Foreign Lawyers after AI-generated false citations in his SRA defence

On 25 August 2026 the Solicitors Disciplinary Tribunal struck Abhishek Kumar off the Register of Foreign Lawyers after finding proved that his 12 March 2026 Answer to the SRA's Rule 12 Statement contained misleading quotations and citations produced with generative AI — including a non-existent 'SRA v Chan [2020] EWHC 1502' and a miscited 'SRA v James, MacGregor & Naylor [2018] EWCA Civ 1420' that is actually an intellectual-property case — and that his 9 April 2026 email admitting AI use was itself AI-drafted with further errors. The tribunal said it would have struck him off on that allegation alone; the parallel ground was his January 2024 conviction under s.21 of the Immigration, Asylum and Nationality Act 2006. This is the SDT's first case on a lawyer's use of AI, per the SRA's counsel.

If you or someone you know is struggling, free and confidential support is available. Find a helpline near you at Signpost.

Back to all incidents