What was hallucinated

Fabricated: Case Law | Enviro cited a Tribunal decision titled 'MDS Nordion (PR-2001-041)' as precedent; the Tribunal found this decision does not appear to exist. || Misrepresented: Legal Norm | Enviro cited article 506(6) of the CFTA and characterized it as requiring that 'the criteria be applied in a transparent and objective manner'; the Tribunal found that article 506(6) instead lists elements that tender notices must include and does not read as Enviro claimed.

Sanction teardown · Canadian ITT, Canada · 2025-06-26

Enviro Plus Duct Cleaning v. Department of Public Works

What happened

In Canadian ITT, 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)

Enviro cited a Tribunal decision titled 'MDS Nordion (PR-2001-041)' as precedent; the Tribunal found this decision does not appear to exist.
Misrepresented (Legal Norm)

Enviro cited article 506(6) of the CFTA and characterized it as requiring that 'the criteria be applied in a transparent and objective manner'; the Tribunal found that article 506(6) instead lists elements that tender notices must include and does not read as Enviro claimed.

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

Not specified in source record.

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/1722/Enviro-Plus-Duct-Cleaning-2025-CanLII-59520-CA-CITT.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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