The single documented sanction on record in Ontario Court of Justice (OCJ) concluded with a Court Found Filings Bore Hallmarks Of Ai-generation; Ordered Procedural Restrictions (10-page Limit, Signed Affidavit Attesting Authorship), Gave Non-compliant Ai-tinged Filings Little To No Weight, Warned Of Sanctions; No Monetary Or Professional Sanctions Imposed. tied to Unidentified as the implicated tool. One case is not a trend, but it establishes that this court has already surfaced the fabricated-citation issue on the docket — every subsequent filing in Ontario Court of Justice (OCJ) is on notice.
The rulings in this jurisdiction are consistent with the pattern Citation Safe tracks nationally: when a court identifies a fabricated citation, the sanction almost always follows within days, not weeks. The attorney of record — not the AI — is on the hook. Rule 11 (federal), state analogs, and inherent authority all support monetary sanctions, disgorgement, adverse-costs orders, and bar referrals independent of the tool that produced the citation.
Practical implication: any brief that reaches a docket in Ontario Court of Justice (OCJ) needs a citation-existence check before filing. Existence is Layer 1 — the case has to be real. Layer 2 is quote accuracy (any quoted language must actually appear in the opinion). Layer 3 is propositional support (the opinion must actually stand for what you cite it for). Every documented sanction below failed at Layer 1 or Layer 2 — the kind of failure that is trivially catchable before filing and catastrophically visible after.