Sanction teardown · Human Rights Tribunal of Ontario, Canada · 2025-11-21
Walker v. Collingwood General and Marine Hospital
What happened
In Human Rights Tribunal of Ontario, 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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Misrepresented (Case Law)Applicant cited 'Dhanjal v. Air Canada, 2016 HRTO 1301' as HRTO authority; Tribunal located Dhanjal as a 1996 CHRT decision (CanLII 2385) and not as the HRTO citation provided, indicating a misattribution of the source.
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Fabricated (Case Law)Applicant cited 'Sokoloff v. Tru-Path Occupational Therapy Services Ltd., 2013 HRTO 539' as an HRTO decision and for the proposition that limitation periods do not run while discrimination continues; Tribunal found no such HRTO decision and the citation does not exist on CanLII.
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Misrepresented (Case Law)Applicant cited 'Turner v. Canada Border Services Agency, 2017 HRTO 211' as Tribunal authority; Tribunal located a Turner decision but as 2020 CHRT 1 (Canadian Human Rights Tribunal), not as the HRTO citation provided, indicating a misattributed precedent.
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
Request for Reconsideration denied
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.
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Source: https://www.damiencharlotin.com/documents/1082/Walker_v._Collinwood_Canada_21_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).