Quebec Court of Appeal orders costs against a self-represented appellant whose AI-drafted filings cited two non-existent judgments (1 Oct 2026)

The filings. On 15 December 2025 a self-represented party appealed the penalty imposed on him for contempt of court in a divorce proceeding. In her brief the respondent asked for $10,000 in damages, alleging that he had included non-existent legal references generated by artificial intelligence in his filings. In ruling on that request, the Court of Appeal described his notice of appeal and his brief as written with artificial intelligence and as containing two references to non-existent judgments and one inaccurate reference to a cited paragraph. The decision does not name the tool or quote its output.

The ruling on AI use. The court held that using artificial intelligence to draft appeal filings is not prohibited, but that parties, including unrepresented ones, must use it rigorously and comply with the Chief Justice's notice on AI, which makes the litigant responsible for verifying the information it supplies. It found that the appellant had breached that notice and that his conduct amounted to negligence rather than bad faith. It distinguished an earlier 2026 case in which the appellant had known of the invented references and was ordered to pay $1,000. Because knowledge was not shown here, it rejected the separate monetary sanction but held that the conduct still had to be sanctioned, and ordered court costs against him under article 340 C.p.c., which in family matters otherwise leaves each party to bear its own costs.

The rest of the appeal. For reasons unrelated to AI (the first-instance judge had linked an unpaid sum that was not part of the contempt to the imprisonment), the court partly allowed the appeal and substituted 100 hours of community work and 30 days of coercive imprisonment for 175 hours and 60 days.

The Quebec Court of Appeal ordered court costs against the self-represented appellant as a sanction for filings he drafted with AI that cited non-existent judgments, holding that he breached the court's AI notice through negligence (2026 QCCA 1300, 1 October 2026). The amount of the costs is not stated.

The Quebec Court of Appeal (2026 QCCA 1300, 1 October 2026) held that the appellant breached the Chief Justice of Quebec's notice on the use of artificial intelligence before the Court of Appeal, found his conduct negligent rather than in bad faith, rejected the respondent's claim for $10,000 in damages for a serious breach in the conduct of the proceeding, and ordered costs in favour of the respondent under article 340 of the Code of Civil Procedure. On the merits it partly allowed the appeal and reduced the contempt penalty from 175 to 100 hours of community work and the coercive imprisonment from 60 to 30 days.