What was hallucinated

Fabricated: Case Law | Rewa advanced a non-existent expansive disclosure test (“train of inquiry” relevance) attributed to the fabricated MacMillan Bloedel case; the court found the legal proposition itself to be non-existent. || Fabricated: Case Law | Rewa mis-cited CIBC World Markets Inc. v. Genuity Capital Markets as 2011 ONCA 525; the court noted the real case is 2005 CanLII 3944 (ONSC) on injunctions and unrelated to his issues. || Fabricated: Case Law | Rewa mis-cited Deloitte & Touche v. Livent Inc. as 2017 ONCA 575; the court noted the real case is 2016 ONCA 395 on duty of care and unrelated to his motion. || Misrepresented: Case Law | Rewa relied on Premform Ltd. v. Heights (R) Ltd., 2023 ONSC 955 for propositions it does not support; the court said it concerned admissibility of evidence not previously disclosed, not his issues.

Sanction teardown · Ontario SJC, Canada · 2025-08-01

Halton (Regional Municipality) v. Rewa et al.

What happened

In Ontario SJC, 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)

Rewa advanced a non-existent expansive disclosure test (“train of inquiry” relevance) attributed to the fabricated MacMillan Bloedel case; the court found the legal proposition itself to be non-existent.
Fabricated (Case Law)

Rewa mis-cited CIBC World Markets Inc. v. Genuity Capital Markets as 2011 ONCA 525; the court noted the real case is 2005 CanLII 3944 (ONSC) on injunctions and unrelated to his issues.
Fabricated (Case Law)

Rewa mis-cited Deloitte & Touche v. Livent Inc. as 2017 ONCA 575; the court noted the real case is 2016 ONCA 395 on duty of care and unrelated to his motion.
Misrepresented (Case Law)

Rewa relied on Premform Ltd. v. Heights (R) Ltd., 2023 ONSC 955 for propositions it does not support; the court said it concerned admissibility of evidence not previously disclosed, not his issues.

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

Motion adjourned, opposing party's costs to be compensated (monetary penalty: 1 CAD.)

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/651/Halton_Regional_Municipality_v._Rewa_et_al._Canada_1_August_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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