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In the Matter of a Hearing by a Panel of the Discipline Committee into the conduct of Denis Sawyer

Court
Law Society of New Brunswick Discipline Committee
Jurisdiction
Canada
Decided
2026-07-22
AI tool
Implied
Outcome
Notice of Complaint filed
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Filed a brief with the New Brunswick Provincial Court containing ten fictitious citations (10 of 12 citations in the brief were fabricated); later removed most but left two. || Fabricated: Case Law | After a revised filing, two fictitious citations remained; to one of these he attributed a quote.

Details

The Law Society alleges Mr. Denis Sawyer submitted a brief to the New Brunswick Provincial Court containing fictitious citations (ten of twelve citations were fabricated). After being informed, he filed a revised brief removing most but leaving two fictitious citations, one of which he attributed a quote. The complaint also alleges he used generative AI in preparing briefs and failed to properly review the outputs. The Law Society has charged breaches of multiple professional conduct rules and referred the matter to a Discipline Committee hearing; Mr. Sawyer disavowed the briefs at the hearing.

Sanction teardown · Law Society of New Brunswick Discipline Committee, Canada · 2026-07-22

In the Matter of a Hearing by a Panel of the Discipline Committee into the conduct of Denis Sawyer

What happened

In Law Society of New Brunswick Discipline Committee, 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)
    Filed a brief with the New Brunswick Provincial Court containing ten fictitious citations (10 of 12 citations in the brief were fabricated); later removed most but left two.
  • Fabricated (Case Law)
    After a revised filing, two fictitious citations remained; to one of these he attributed a quote.

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

Notice of Complaint filed

Additional detail

The Law Society alleges Mr. Denis Sawyer submitted a brief to the New Brunswick Provincial Court containing fictitious citations (ten of twelve citations were fabricated). After being informed, he filed a revised brief removing most but leaving two fictitious citations, one of which he attributed a quote. The complaint also alleges he used generative AI in preparing briefs and failed to properly review the outputs. The Law Society has charged breaches of multiple professional conduct rules and referred the matter to a Discipline Committee hearing; Mr. Sawyer disavowed the briefs at the hearing.

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/2718/Notice-of-Complaint-by-the-Law-Society-of-New-Brunswick.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2718/Notice-of-Complaint-by-the-Law-Society-of-New-Brunswick.pdf

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