Sanction teardown · Ontario Court of Justice (OCJ), Canada · 2026-07-24
Brantford (City) v. Doolittle, 2026 ONCJ 440
What happened
In Ontario Court of Justice (OCJ), 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:
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Fabricated (Case Law)Court found defendant's summaries lacked full copies of cited authorities and defendant could not produce sources, suggesting citations may be fabricated or invented by AI.
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Misrepresented (Case Law)AI-generated case summaries did not properly digest or state the ratio decidendi of cited decisions, misrepresenting precedents' holdings.
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
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.
Additional detail
The justice found the defendant's written submissions exhibited hallmarks of AI-generation and that his case summaries often lacked full copies of cited authorities and failed to capture the ratio decidendi, raising concern that citations or summaries could be inaccurate or fabricated. The defendant admitted using AI tools but did not identify a specific tool. The court responded by imposing filing limits, requiring a signed affidavit attesting authorship, giving impugned submissions little to no weight, and warning of further sanctions if the conduct continued.
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.
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Source: https://www.damiencharlotin.com/documents/2768/Brantford-City-v.-Doolittle-2026-ONCJ-440.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).