Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 15, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · Nova Scotia Labour Board, Canada · 2026-09-15

Jamieson v Halifax Regional Centre for Education

What happened

In Nova Scotia Labour Board, 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 appellant cited a nonexistent decision and attributed a three-part reprisal test to it. The Board verified that the case did not exist, that file 2209 was unrelated, and that the stated test differed from the genuine Wooten authority.

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

Appeal dismissed; the Officer’s decision was upheld. No specific sanction was imposed for the fabricated authority.

Additional detail

The self-represented appellant relied on a purported decision, “Wootton v. Nova Scotia (Department of Labour), Nova Scotia Labour Board Decision 2209,” and attributed a legal test to it. The Board found that the cited case did not exist and that Board file 2209 concerned an unrelated matter; the asserted test also differed meaningfully from the genuine Wooten authority. Counsel for HRCE identified the problem, and the Board warned that authorities must be authenticated, reproduced, and any generative-AI use disclosed. The Board nevertheless dismissed the appeal on the merits and imposed no separate sanction for the hallucinated authority.

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/3067/Jamieson-v-Halifax-Regional-Centre-for-Education-2026-NSLB-131.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).