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H.B. v. Conseil des écoles publiques de l’Est de l’Ontario

Court
HRTO
Jurisdiction
Canada
Decided
2026-04-14
AI tool
Implied
Outcome
Ordered applicant to provide digital copies of all case law they intend to rely on
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Applicant cited 'Shah v. Toronto DSB, 2021 HRTO 342'; tribunal could not retrieve that case and found the citation corresponded to a different decision (Awad v Petrakos), concluding the reference was AI-generated fake case law. || Fabricated: Legal Norm | Applicant referred to 'Rule 25.11'; tribunal noted no such rule exists in the Human Rights Code or Tribunal Rules and that reference was false/non-existent.

Sanction teardown · HRTO, Canada · 2026-04-14

H.B. v. Conseil des écoles publiques de l’Est de l’Ontario

What happened

In HRTO, 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)
    Applicant cited 'Shah v. Toronto DSB, 2021 HRTO 342'; tribunal could not retrieve that case and found the citation corresponded to a different decision (Awad v Petrakos), concluding the reference was AI-generated fake case law.
  • Fabricated (Legal Norm)
    Applicant referred to 'Rule 25.11'; tribunal noted no such rule exists in the Human Rights Code or Tribunal Rules and that reference was false/non-existent.

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

Ordered applicant to provide digital copies of all case law they intend to rely on

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/2029/H.B.-v.-Conseil-des-ecoles-publiques-de-lEst-de-lOntario-2026-HRTO-571.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2029/H.B.-v.-Conseil-des-ecoles-publiques-de-lEst-de-lOntario-2026-HRTO-571.pdf

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