Skip to main content
Citation Safe

Was ARIH Québec c. Santé Québec on the other side of your case?

Check their next brief before they file — Opposition Check verifies every citation in a filed brief for $49, no signup. Get Opposition Check →

ARIH Québec c. Santé Québec

Court
Québec CS
Jurisdiction
Canada
Decided
2026-04-22
AI tool
Implied
Outcome
Arbitral award annulled because the award relied on nonexistent ('hallucinated') authorities.
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Arbitral reliance on an alleged arbitral decision 'Arbitrage CHU Ste‑Justine (D.T.E. 2018-30)'; SOQUIJ and the Court confirmed this arbitral decision does not exist. || Fabricated: Doctrinal Work | Arbitral footnote citing a doctrinal piece attributed to Frédéric Bachand; Court found the referenced article/book chapter introuvable and not substantiating the tribunal's point. || Fabricated: Case Law | Arbitral citation to a Court of Appeal decision listed as supporting contractual time‑limits; Court found the cited 'Ville de Montréal c. Syndicat des cols bleus regroupés de Montréal, 2005 QCCA 591' to be nonexistent/the neutral reference refers to another case. || Fabricated: Case Law | Arbitral reference to 'Groleau et Groupe Pages Jaunes Cie, 2011 QCCS 5386' which the Court determined does not exist and the citation number leads to a different decision. || Fabricated: Case Law | Arbitral citation to 'Tremblay c. Commission scolaire de la Jonquière, 2002 CanLII 24357 (QCCA)' found by the Court to be nonexistent/the neutral reference points elsewhere.

Sanction teardown · Québec CS, Canada · 2026-04-22

ARIH Québec c. Santé Québec

What happened

In Québec CS, 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)
    Arbitral reliance on an alleged arbitral decision 'Arbitrage CHU Ste‑Justine (D.T.E. 2018-30)'; SOQUIJ and the Court confirmed this arbitral decision does not exist.
  • Fabricated (Doctrinal Work)
    Arbitral footnote citing a doctrinal piece attributed to Frédéric Bachand; Court found the referenced article/book chapter introuvable and not substantiating the tribunal's point.
  • Fabricated (Case Law)
    Arbitral citation to a Court of Appeal decision listed as supporting contractual time‑limits; Court found the cited 'Ville de Montréal c. Syndicat des cols bleus regroupés de Montréal, 2005 QCCA 591' to be nonexistent/the neutral reference refers to another case.
  • Fabricated (Case Law)
    Arbitral reference to 'Groleau et Groupe Pages Jaunes Cie, 2011 QCCS 5386' which the Court determined does not exist and the citation number leads to a different decision.
  • Fabricated (Case Law)
    Arbitral citation to 'Tremblay c. Commission scolaire de la Jonquière, 2002 CanLII 24357 (QCCA)' found by the Court to be nonexistent/the neutral reference points elsewhere.

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

Arbitral award annulled because the award relied on nonexistent ('hallucinated') authorities.

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/2037/2026qccs1360.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2037/2026qccs1360.pdf

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checkerBack to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49Sanctions-motion template