{"meta":{"exportedAt":"2026-10-23T08:51:17.339Z","formatVersion":2,"selection":{"q":"canada","system":"","harm":"","context":"","country":"","role":"","relation":"core","evidence":"","year":"","response":"regulatory","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":2,"coverage":{"cases":2,"countries":1,"languages":2,"unknownLocation":0,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":2,"minors":0,"coreRelations":2,"contextualRelations":1,"mixedRelations":1,"unknownRelations":0,"relationPending":0,"relationUnknown":0},"countingNote":"Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.","affectedCountNote":"Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.","source":"AI incidents","publisher":"NOPE","url":"https://nope.net/incidents","license":"CC BY 4.0"},"incidents":[{"id":"2025-quebec-appeal-court-costs-self-represented-appellant-ai-drafted-filings-nonexistent-judgments","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'Elle réclame aussi 10 000 $ en dommages-intérêts'; 'références juridiques inexistantes générées par l’intelligence artificielle dans ses actes de procédure'","relation":"supports","source_id":"s1"}],"assertion":"The respondent asked the Court of Appeal for $10,000 in damages, alleging that the appellant had included non-existent legal references generated by artificial intelligence in his filings.","causal_attribution":"The decision documents that the respondent made this request; the allegation is hers."},{"id":"c2","status":"documented","evidence":[{"locator":"'parce qu’il a utilisé l’intelligence artificielle pour la rédaction'; 'déclaration d’appel et de son exposé, qui comportent deux références à des arrêts inexistants et une référence inexacte quant à un paragraphe cité'; 'L’appelant a contrevenu à cet Avis de la Juge en chef'; 'une forme de négligence plutôt que de la mauvaise foi'","relation":"supports","source_id":"s1"}],"assertion":"Ruling on the respondent's request, the court described the appellant's notice of appeal and brief as written with artificial intelligence and as containing two references to non-existent judgments and one inaccurate reference to a cited paragraph, and found that he had breached the Chief Justice's notice on AI use through negligence rather than bad faith.","causal_attribution":"Finding stated in the Court of Appeal decision of 1 October 2026; the decision does not name the tool."},{"id":"c3","status":"documented","evidence":[{"locator":"'une telle connaissance de la part de l’appelant n’a pas été démontrée'; 'il y a lieu de le condamner aux frais de justice en vertu de l’article 340 C.p.c.'; 'en matière familiale, de chacune'; 'REJETTE la demande visant à sanctionner un manquement au déroulement'; 'LE TOUT, avec les frais de justice en faveur de l’intimée.'","relation":"supports","source_id":"s1"}],"assertion":"Because knowledge of the invented references was not shown, the court rejected the separate monetary sanction but ordered court costs against the appellant under article 340 C.p.c. to sanction the conduct.","causal_attribution":"Disposition stated in the decision; the costs are the court's response to the AI-drafted filings."},{"id":"c4","status":"documented","evidence":[{"locator":"'ACCUEILLE en partie l’appel'; 'peine de 100 heures de travail d’utilité sociale'; 'une mesure coercitive d’emprisonnement de 30 jours'","relation":"supports","source_id":"s1"}],"assertion":"On the merits the court partly allowed the appeal for reasons unrelated to AI and reduced the contempt penalty to 100 hours of community work and 30 days of coercive imprisonment.","causal_attribution":"Disposition stated in the decision; the contempt arose from non-compliance with family-court orders, not from AI use."}],"effects":[{"label":"a self-represented appellant was ordered to pay court costs because his AI-drafted appeal filings cited non-existent judgments","claim_id":"c3","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.damiencharlotin.com/documents/3266/Droit-de-la-famille-261553-2026-QCCA-1300.pdf","kind":"court_record","access":"read","language":"fr","translation_note":"Read in full in French by the research agent (an AI) on 2026-10-12 from the copy of the decision hosted by the AI Hallucination Cases database (PDF, HTTP 200, text extracted with pdftotext); the English assertions are the agent's translation and no human translator or reviewer was involved. The locators quote the French original.","independence_group":"qcca-2026-qcca-1300-decision"}],"version":1,"ai_roles":["own_use"],"contexts":["justice","relationships"],"unknowns":["Which AI tool the appellant used and what it produced beyond the two non-existent judgments and the inaccurate paragraph reference.","The amount of the court costs ordered against the appellant.","Whether the appellant has complied with the underlying orders or served the coercive imprisonment."],"geography":{"basis":"The appeal was heard and decided by the Quebec Court of Appeal from a Quebec Superior Court judgment (decision caption and paragraph 1), and the filings were made in that court. The decision states no residence for the appellant, so affected_person_countries is left empty.","court_countries":["CA"],"event_countries":["CA"],"affected_person_countries":[]},"publication":{"basis":"Published on the court's own decision: the Quebec Court of Appeal described a self-represented appellant's appeal filings as written with AI and as citing non-existent judgments, held that he had breached its AI notice and ordered costs against him. The facts are documented by the decision; the appellant is a private party in a family matter and is not identified.","reviewed_on":"2026-10-12"},"ai_involvement":{"basis":"Ruling on the respondent's request (paragraph 28), the Quebec Court of Appeal decision describes the appellant's notice of appeal and brief as written with artificial intelligence and as containing two references to non-existent judgments and an inaccurate paragraph reference. The court treated that AI drafting and those references as established: it held that he had breached its AI notice (paragraph 30), contrasted his lack of shown knowledge of the hallucinations with an earlier case (paragraphs 31-32) and ordered costs against him for that reason. The AI output reached him as drafted text he filed (communicated_with) and informed the court's costs decision about him (informed_decision_about). The decision does not identify the tool or quote its output.","status":"supported"},"person_relations":["communicated_with","informed_decision_about"]},"name":"Quebec Court of Appeal orders costs against a self-represented appellant whose AI-drafted filings cited two non-existent judgments (1 Oct 2026)","summary":"On 1 October 2026 the Quebec Court of Appeal ordered court costs against a self-represented appellant in a family-law contempt appeal as a sanction for appeal filings that, in the court's description, he had written with artificial intelligence and that contained two references to non-existent judgments and one inaccurate reference to a cited paragraph. The court held that AI may be used to draft appeal filings only if the litigant verifies the authorities, found that he had breached the Chief Justice's notice on AI use, and described his conduct as negligence rather than bad faith. It rejected the respondent's request for a separate $10,000 sanction and, for reasons unrelated to AI, reduced the contempt penalty imposed at first instance. The decision does not name the AI tool.","incidentDate":"2025-12-15","incidentEndDate":"2026-10-01","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"single_interaction","reportedDate":"2026-10-01","aiSystem":"Artificial intelligence, not identified in the decision, which the self-represented appellant used to draft his notice of appeal and brief","aiProduct":"Unidentified AI drafting tool","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm"],"harmOutcomeSummary":"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.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"One person: the self-represented appellant who used AI to draft the filings and against whom costs were ordered. The respondent and other family members are not counted as harmed by the AI-related sanction.","victimAgeRange":"adult","jurisdiction":"CA","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://www.damiencharlotin.com/documents/3266/Droit-de-la-famille-261553-2026-QCCA-1300.pdf","primarySourceLabel":"Quebec Court of Appeal, Droit de la famille — 261553, 2026 QCCA 1300, 1 October 2026 (copy hosted by the AI Hallucination Cases database)","firstPublishedAt":"2026-10-12T03:17:20.356128+00:00","updatedAt":"2026-10-12T03:17:20.356128+00:00","scopeVersion":"facts-v3","tags":["hallucinated_citations","courts","self_represented_litigant","costs_order","family_law","canada","quebec"]},{"id":"2025-ontario-lawyer-chatgpt-factum-invented-cases-contempt-referral-licence-suspension","caseFacts":{"claims":[{"id":"c1","status":"reported","evidence":[{"locator":"'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.'","relation":"supports","source_id":"s1"},{"locator":"'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.'","relation":"supports","source_id":"s2"},{"locator":"'When Justice Myers confronted her in open court about whether she had used ChatGPT, she categorically denied it, stating, “I did not.”'","relation":"supports","source_id":"s4"},{"locator":"'whether she had used ChatGPT to write her factum'; 'said she had not.'","relation":"supports","source_id":"s7"}],"assertion":"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."},{"id":"c2","status":"reported","evidence":[{"locator":"'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.'","relation":"supports","source_id":"s2"},{"locator":"'counsel was ordered to return for a show cause hearing to argue why she should not be cited for contempt of court'","relation":"supports","source_id":"s3"}],"assertion":"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."},{"id":"c3","status":"reported","evidence":[{"locator":"'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'","relation":"supports","source_id":"s3"},{"locator":"'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,'","relation":"supports","source_id":"s7"}],"assertion":"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."},{"id":"c4","status":"reported","evidence":[{"locator":"'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'","relation":"supports","source_id":"s4"},{"locator":"'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.'","relation":"supports","source_id":"s5"}],"assertion":"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."},{"id":"c5","status":"reported","evidence":[{"locator":"'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.'","relation":"supports","source_id":"s6"}],"assertion":"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."},{"id":"c6","status":"reported","evidence":[{"locator":"'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.'","relation":"supports","source_id":"s7"}],"assertion":"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."}],"effects":[{"label":"show-cause order for contempt, referral for criminal contempt and a six-month licence suspension after relying on ChatGPT-generated nonexistent case law","claim_id":"c5","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.canadianlawyermag.com/practice-areas/family/superior-court-says-family-law-case-factum-may-have-fake-legal-citations-due-to-ai-hallucinations/392433","kind":"news_report","access":"read","language":"en","translation_note":"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.","independence_group":"ontario-superior-court-endorsements-2025"},{"id":"s2","url":"https://www.lawnext.com/2025/05/ai-hallucinations-strike-again-two-more-cases-where-lawyers-face-judicial-wrath-for-fake-citations.html","kind":"news_report","access":"read","language":"en","translation_note":"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.","independence_group":"ontario-superior-court-endorsements-2025"},{"id":"s3","url":"https://cassels.com/insights/fantasies-in-the-footnotes-ontario-court-rebukes-counsel-for-fake-and-misleading-ai-generated-case-citations/","kind":"legal_commentary","access":"read","language":"en","translation_note":"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.","independence_group":"ontario-superior-court-endorsements-2025"},{"id":"s4","url":"https://www.law360.ca/ca/articles/2419185","kind":"legal_commentary","access":"read","language":"en","translation_note":"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).","independence_group":"ontario-superior-court-endorsements-2025"},{"id":"s5","url":"https://www.weirfoulds.com/pdf-article?id=36828","kind":"legal_commentary","access":"read","language":"en","translation_note":"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.","independence_group":"ontario-superior-court-endorsements-2025"},{"id":"s6","url":"https://www.lawtimesnews.com/resources/professional-regulation/law-society-tribunal-temporarily-suspends-lawyers-license-after-finding-she-lied-about-chatgpt-use/393450","kind":"news_report","access":"read","language":"en","translation_note":"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.","independence_group":"law-society-tribunal-order-and-reasons-2026"},{"id":"s7","url":"https://www.lawtimesnews.com/resources/professional-regulation/out-of-character-tribunal-explains-six-month-suspension-of-lawyer-who-lied-about-chatgpt-use/393453","kind":"news_report","access":"read","language":"en","translation_note":"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.","independence_group":"law-society-tribunal-order-and-reasons-2026"}],"version":1,"ai_roles":["own_use"],"contexts":["justice","work"],"unknowns":["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."],"geography":{"basis":"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.","court_countries":["CA"],"event_countries":["CA"],"affected_person_countries":["CA"]},"publication":{"basis":"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.","reviewed_on":"2026-10-12"},"ai_involvement":{"basis":"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.","status":"reported"},"person_relations":["communicated_with"]},"name":"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","summary":"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.","incidentDate":"2025-05-01","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"single_interaction","reportedDate":"2025-05-13","aiSystem":"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","aiProduct":"ChatGPT","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm","legal_harm","reputational_harm"],"harmOutcomeSummary":"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.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"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.","victimAgeRange":"adult","jurisdiction":"CA","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"ongoing","primarySourceUrl":"https://www.lawtimesnews.com/resources/professional-regulation/out-of-character-tribunal-explains-six-month-suspension-of-lawyer-who-lied-about-chatgpt-use/393453","primarySourceLabel":"Law Times, 21 Jul 2026: tribunal explains six-month suspension of lawyer who lied about ChatGPT use","firstPublishedAt":"2026-10-12T03:13:48.661937+00:00","updatedAt":"2026-10-12T03:13:48.661937+00:00","scopeVersion":"facts-v3","tags":["hallucinated_citations","courts","lawyer_sanction","contempt_of_court","professional_discipline","canada","ontario"]}]}