Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided July 10, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · Federal Court, Canada · 2026-07-10

JEAN LUCIEN KIBONDO KILONGOZI v THE MINISTER OF CITIZENSHIP AND IMMIGRATION

What happened

In Federal Court, 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)

Adopter's submissions cited a non-existent Federal Court of Appeal decision; the Court expressly found the decision to be inexistent.

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 identified the cited authority as non-existent and treated it as unreliable; no professional sanction or monetary penalty was imposed related to the fabricated citation.

Additional detail

In responding to a procedural fairness letter, the adopter (through submissions) cited a purported Federal Court of Appeal decision "Stum c Canada (Ministre de la Citoyenneté et de l’Immigration), 2004 CAF 148," which the Court found to be an inexistent decision (a fabricated citation). The Court noted the citation was not real, disregarded it when assessing the fairness and reasonableness of the officer's process, and proceeded without imposing any sanction. The Court relied on the existing record and contemporaneous GCMS notes rather than the fabricated 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/2908/Kibondo-Kilongozi-v.-Canada-Citizenship-and-Immigration-2026-FC-928.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).