What was hallucinated

Fabricated: Case Law | Monitor identified and court found that 'Valgardson v. British Columbia, 2020 BCCA 20' does not exist; cited by Mr. Schaller in his factum and characterized as an AI-generated fabricated case. || Misrepresented: Case Law | Mr. Schaller cited 'Wallace v. Crates Marine Sales Ltd. 2014 ONSC 3124' for a proposition about balancing fairness/efficiency/access to justice; the court noted the cited decision does not exist as cited and the actual similar authority (Wallace v. Crate’s Marine Sales Ltd., 2014 ONCA 671) does not stand for that proposition. || Fabricated: Other | Monitor flagged a number of other authorities cited by Mr. Schaller that either could not be found or did not support the propositions for which they were cited.

Sanction teardown · Ontario SCJ, Canada · 2025-10-28

The Vancor Group Inc. v. 2744364 Ontario Limited et al

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)

Monitor identified and court found that 'Valgardson v. British Columbia, 2020 BCCA 20' does not exist; cited by Mr. Schaller in his factum and characterized as an AI-generated fabricated case.
Misrepresented (Case Law)

Mr. Schaller cited 'Wallace v. Crates Marine Sales Ltd. 2014 ONSC 3124' for a proposition about balancing fairness/efficiency/access to justice; the court noted the cited decision does not exist as cited and the actual similar authority (Wallace v. Crate’s Marine Sales Ltd., 2014 ONCA 671) does not stand for that proposition.
Fabricated (Other)

Monitor flagged a number of other authorities cited by Mr. Schaller that either could not be found or did not support the propositions for which they were cited.

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

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/1733/The-Vancor-Group-Inc.-v.-2744364-Ontario-Limited-et-al-2025-ONSC-5925.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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