Sanction teardown · NS SC, Canada · 2026-04-28

Mazac v. Muise

What happened

In NS SC, 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)
  Brief cited 'Darkallah v. Walsh, 2015 NSSM 35'—court found no Walsh decision and that the citation was a non-existent case likely generated by AI; the intended case was Darkallah v. 3223701 Canada Inc., 2016 QCCS 3245.
• Fabricated (Case Law)
  Brief cited 'Frawley v. Rawleigh, 2012 NSSC 213'—court found this citation incorrect/non-existent in that form and not supporting the principle asserted; AI use likely produced the erroneous citation (intended: Frawley v. Buckley (1988)).
• Fabricated (Case Law)
  Multiple other misplaced citations to non-existent cases in the September 18, 2025 brief increased defendant's research burden; court concluded these were more likely AI-generated than clerical errors.

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

Increased Costs Award (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/2095/Mazac-v.-Muise-2026-NSSC-138.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).