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Alana Kotler v Ontario Secondary School Teachers’ Federation

Court
Ontario Labour Relations Board
Jurisdiction
Canada
Decided
2025-08-29
AI tool
Implied
Outcome
Arguments ignored
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited. || Misrepresented: Case Law | Applicant relied on Micheal Lind v. International Alliance...; the Board located a decision with the same locator but it is a brief procedural decision that does not support the proposition relied upon by the applicant (misrepresented). || Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited. || Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited. || Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited. || Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited. || Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited (Latreille appears again in another citation form). || Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited (Hargrave variant cited by applicant not located). || Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited. || Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited (external tribunal decisions cited but not located). || Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited (external tribunal decision cited but not located). || Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited. || Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited (board could not locate the Millen decision as cited). || Fabricated: Case Law | Unreported decision cited by applicant that the Board could not locate as cited. || Fabricated: Case Law | Recent external decision cited by applicant that the Board and OSSTF could not locate as cited.

Details

The applicant relied on numerous case citations that the Board and OSSTF could not locate as cited; one located decision did not support the proposition relied upon. Applicant acknowledged possible citation errors and was asked to provide copies but objected. The Board refused to rely on unlocatable authorities and dismissed the application.

Sanction teardown · Ontario Labour Relations Board, Canada · 2025-08-29

Alana Kotler v Ontario Secondary School Teachers’ Federation

What happened

In Ontario Labour Relations 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)
    Case cited by applicant could not be located by the Board or OSSTF as cited.
  • Misrepresented (Case Law)
    Applicant relied on Micheal Lind v. International Alliance...; the Board located a decision with the same locator but it is a brief procedural decision that does not support the proposition relied upon by the applicant (misrepresented).
  • Fabricated (Case Law)
    Case cited by applicant could not be located by the Board or OSSTF as cited.
  • Fabricated (Case Law)
    Case cited by applicant could not be located by the Board or OSSTF as cited.
  • Fabricated (Case Law)
    Case cited by applicant could not be located by the Board or OSSTF as cited.
  • Fabricated (Case Law)
    Case cited by applicant could not be located by the Board or OSSTF as cited.
  • Fabricated (Case Law)
    Case cited by applicant could not be located by the Board or OSSTF as cited (Latreille appears again in another citation form).
  • Fabricated (Case Law)
    Case cited by applicant could not be located by the Board or OSSTF as cited (Hargrave variant cited by applicant not located).
  • Fabricated (Case Law)
    Case cited by applicant could not be located by the Board or OSSTF as cited.
  • Fabricated (Case Law)
    Case cited by applicant could not be located by the Board or OSSTF as cited (external tribunal decisions cited but not located).
  • Fabricated (Case Law)
    Case cited by applicant could not be located by the Board or OSSTF as cited (external tribunal decision cited but not located).
  • Fabricated (Case Law)
    Case cited by applicant could not be located by the Board or OSSTF as cited.
  • Fabricated (Case Law)
    Case cited by applicant could not be located by the Board or OSSTF as cited (board could not locate the Millen decision as cited).
  • Fabricated (Case Law)
    Unreported decision cited by applicant that the Board could not locate as cited.
  • Fabricated (Case Law)
    Recent external decision cited by applicant that the Board and OSSTF could not locate as cited.

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

Arguments ignored

Additional detail

The applicant relied on numerous case citations that the Board and OSSTF could not locate as cited; one located decision did not support the proposition relied upon. Applicant acknowledged possible citation errors and was asked to provide copies but objected. The Board refused to rely on unlocatable authorities and dismissed the application.

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/974/2025canlii96840_NRiY2XS.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/974/2025canlii96840_NRiY2XS.pdf

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