Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided October 1, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · Quebec Court of Appeal, Canada · 2026-10-01

Droit de la famille — 261553

What happened

In Quebec Court of Appeal, 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)

The appeal materials cited a judgment that did not exist. The court identified the reference as fabricated and treated it as a failure to verify AI-generated legal authorities.
Fabricated (Case Law)

The appeal materials cited a second judgment that did not exist. The court identified the reference as fabricated and treated it as a failure to verify AI-generated legal authorities.
Misrepresented (Case Law)

The appeal materials contained an inaccurate reference to the paragraph of an authority being cited. The court noted the erroneous paragraph reference but did not impose the requested $10,000 sanction.

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

The court found that the self-represented appellant used AI negligently without verifying the authorities. It ordered costs in favor of the respondent under article 340 C.C.P., but rejected the requested $10,000 monetary sanction.

Additional detail

The appellant’s appeal materials, prepared using artificial intelligence, contained two references to nonexistent judgments and one inaccurate reference to a cited paragraph. The Court of Appeal held that AI use is permissible only if the litigant verifies the accuracy of the authorities and complies with the Court’s AI notice. It characterized the conduct as negligence rather than bad faith; unlike a related case involving knowing use of fabricated authorities, the court imposed costs under article 340 C.C.P. rather than a separate $10,000 sanction.

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/3266/Droit-de-la-famille-261553-2026-QCCA-1300.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).