What was hallucinated

Fabricated: Case Law | Citation could not be located in legal databases; tribunal treated the reference as fictitious. || Misrepresented: Case Law | Citation provided (QCCA) was introuvable; an existing Supreme Court decision on the same name addresses unrelated issues — principle misattributed. || Misrepresented: Case Law | Named neutral citation did not correspond to the case cited (mis-citation/misattribution). || Misrepresented: Case Law | Real criminal-law decision cited and used to support unrelated civil procedural principles (misattribution/irrelevant authority). || Misrepresented: Case Law | Neutral/reference citation corresponded to a different decision (mis-citation); the named decision did not support the principle invoked.

Sanction teardown · Québec, Canada · 2026-03-03

Makongo c. Montpetit

What happened

In Québec, 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)

Citation could not be located in legal databases; tribunal treated the reference as fictitious.
Misrepresented (Case Law)

Citation provided (QCCA) was introuvable; an existing Supreme Court decision on the same name addresses unrelated issues — principle misattributed.
Misrepresented (Case Law)

Named neutral citation did not correspond to the case cited (mis-citation/misattribution).
Misrepresented (Case Law)

Real criminal-law decision cited and used to support unrelated civil procedural principles (misattribution/irrelevant authority).
Misrepresented (Case Law)

Neutral/reference citation corresponded to a different decision (mis-citation); the named decision did not support the principle invoked.

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

Monetary Sanction (monetary penalty: 800 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/1710/Makongo-v.-Montpetit-2026-QCCQ-746-compressed.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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