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Law Society of Alberta v. Tiwana

Court
Law Society of Alberta Appeal Panel
Jurisdiction
Canada
Decided
2026-03-12
AI tool
Unidentified
Outcome
AI misuse as aggravating factor for awarding costs
Monetary penalty
1 CAD

What was hallucinated

Fabricated: Case Law | AI-generated hallucinated case cited in appellant's brief; LSA counsel could not locate it and appellant admitted it was a 'placeholder'. || Misrepresented: Case Law | Repeated oral reliance on a Law Society of BC case that was irrelevant and for which the appellant could not provide style of cause or citation; court noted the reference did not support his propositions.

Sanction teardown · Law Society of Alberta Appeal Panel, Canada · 2026-03-12

Law Society of Alberta v. Tiwana

What happened

In Law Society of Alberta Appeal Panel, 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)
    AI-generated hallucinated case cited in appellant's brief; LSA counsel could not locate it and appellant admitted it was a 'placeholder'.
  • Misrepresented (Case Law)
    Repeated oral reliance on a Law Society of BC case that was irrelevant and for which the appellant could not provide style of cause or citation; court noted the reference did not support his propositions.

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

AI misuse as aggravating factor for awarding costs (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/1902/Law-Society-of-Alberta-v-Tiwana-2026-ABLS-7.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1902/Law-Society-of-Alberta-v-Tiwana-2026-ABLS-7.pdf

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