What was hallucinated

Fabricated: Case Law | Factum contained multiple references to non-existent cases generated by AI; court identified these as AI 'hallucinations' that could not be located and warned litigants to verify authorities. || Misrepresented: Case Law | Factum cited existing authorities that were mischaracterized and used to support propositions they did not actually support; court found these to be misrepresentations resulting from AI use. || False Quotes: Case Law | Factum included fabricated quotations and references lacking pinpoint citations (no paragraph/page), which the court identified as another form of AI hallucination.

Sanction teardown · Ontario SCJ, Canada · 2026-06-26

Nady v. Al Sadi, 2026 ONSC 3760

What happened

In Ontario SCJ, 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)

Factum contained multiple references to non-existent cases generated by AI; court identified these as AI 'hallucinations' that could not be located and warned litigants to verify authorities.
Misrepresented (Case Law)

Factum cited existing authorities that were mischaracterized and used to support propositions they did not actually support; court found these to be misrepresentations resulting from AI use.
False Quotes (Case Law)

Factum included fabricated quotations and references lacking pinpoint citations (no paragraph/page), which the court identified as another form of AI hallucination.

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 increasing adverse 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/2541/Nady-v.-Al-Sadi-2026-ONSC-3760.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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