Sanction teardown · King's Bench for Saskatchewan, Canada · 2025-10-15

T.B. v K.M.

What happened

In King's Bench for Saskatchewan, 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 'A.M. v C.H., 2019 SKQB 162, 45 CPC (8th) 212' but the citation actually corresponded to Watch v Live Nation Entertainment Inc.; court found the citation incorrect and the brief unreliable.
• Fabricated (Case Law)
  Brief cited 'Baker v Baker, 2007 ONCA 329, 220 CCC (3d) 74' which the court identified as actually being R v Mariani; citation/name mismatch undermined the brief's trustworthiness.
• Fabricated (Case Law)
  Brief cited 'R.C. v R.C., 2013 NSCA 71, 331 NSR (2d) 151' but the authority was actually Antigonish/Guysborough Federation of Agriculture v Antigonish County (Municipality); court noted the misattribution.
• Fabricated (Case Law)
  Brief cited 'M.K. v S.K., 2010 ABQB 150, 99 CPC (6th) 367' which the court noted was actually Magnus v Condominium Plan No. 9511228; another instance of incorrect citation/name.
• Fabricated (Case Law)
  Brief referenced 'Gordon v Goertz, [1996] 2 SCR 27' but with an incomplete citation; court treated the brief as unreliable in part for this reason.

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

Court declined to award costs to applicant; portions of the reply brief were struck; admonishment

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/975/2025skkb176.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).