Sanction teardown · Federal Court, Canada · 2026-06-11
Myriane Béland v. Procureur général du Canada
What happened
In Federal Court, 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:
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Fabricated (Case Law)The applicant listed 'Mazhero v Canada (Attorney General), 2019 FC 575' among authorities that appeared inaccurate or non-existent and were disregarded by the Court.
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Fabricated (Case Law)The applicant listed 'Crichlow v Canada (Treasury Board), 2010 PSLRB 122' which the respondent flagged as apparently inaccurate/non-existent; the Court omitted it.
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Fabricated (Case Law)The applicant listed 'Baldwin v Canada (Attorney General), 2019 FC 1119' among the questionable authorities; the respondent said it appeared inaccurate and the Court disregarded it.
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Misrepresented (Case Law)Applicant cited 'Kaweesa v Canada, 2019 CF 134' to support a procedural fairness proposition; the neutral citation 2019 CF 134 actually refers to Aguirre Renteria v Canada, a different immigration decision and not supportive of the argument.
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Misrepresented (Case Law)Applicant cited 'Singh v Canada, 2015 CF 120' for a quote on procedural fairness at para. 27; the neutral citation 2015 FC 120 corresponds to Siliya v Canada, an unrelated immigration matter.
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Misrepresented (Case Law)Applicant cited 'Zolotareva v Canada, 2020 CF 95' for the proposition that fairness may require adaptation of procedures; the neutral citation 2020 CF 95 corresponds to Sangha v Canada, not Zolotareva.
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Fabricated (Case Law)The applicant's jurisprudence list included 'Khalil v Canada (Attorney General), 2012 FC 436', which the respondent identified as inaccurate or non-existent and the Court disregarded it.
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Fabricated (Case Law)The applicant listed 'Komolafe v Canada (Minister of Citizenship and Immigration), 2013 FC 802' which was identified as inaccurate/non-existent and ignored by the Court.
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: 500 USD.)
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/2383/Beland-c.-Canada-Procureur-General-2026-CF-779.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).