Incident Tracker
7 verified incidents · as of 2026-09-05
2026-08-12Costs order
Arbuckle v. Tanner, 2026 NSCA 62The Nova Scotia Court of Appeal dismissed a family-law appeal for failure to perfect it and ordered lump-sum costs of CAD 20,000 after the self-represented appellant filed AI-generated transcripts containing invented testimony and a forged transcriber's certificate. Gogan J.A. rejected his explanation that the AI had hallucinated the certification, calling the filing knowingly misleading.
2026-08-11Sanctions
A.P. v. S.K. (Droit de la famille, 261234), 2026 QCCA 1092The Quebec Court of Appeal ordered a self-represented family-law appellant to pay CAD 1,000 under article 342 of the Code of Civil Procedure after he conceded that four cited judgments, including two attributed to the Supreme Court of Canada, were ChatGPT fabrications. The court held that litigants cannot assume AI output is free of hallucinations.
2026-07-16Suspension
Law Society of Ontario v. Lee, 2026 ONLSTH 136The Law Society Tribunal suspended Toronto lawyer Jisuh Lee's licence for six months and ordered CAD 10,000 in costs after she filed a factum containing AI-generated fictitious or irrelevant precedents in a family law proceeding that had become an estate matter. It follows Mazaheri (June 2026) and is reported as Ontario's first licence suspension for AI misuse.
2026-07-10Warning
Kibondo-Kilongozi v. Canada (Citizenship and Immigration), 2026 FC 928In a judicial review in the Federal Court of Canada concerning a Congolese child's adoption-based visa, Justice Gascon expressly found that a Federal Court of Appeal decision cited by the applicants' counsel did not exist. The finding accompanied criticism of counsel's non-compliance with scheduling orders, though the court recorded no separate costs sanction for the fabricated citation.
2025-12-04Regulatory referral
Ko v. Li, 2025 ONSC 2965In Ontario, lawyer Jisuh Lee filed a ChatGPT-fabricated factum, then admitted she had lied about authorship after initially blaming others. Justice Myers referred a criminal-contempt prosecution to Ontario's Attorney General, and the Law Society Tribunal later suspended Lee for six months and ordered CAD 10,000 costs for misconduct including dishonesty.
2025-09-26Costs order
Reddy v Saroya, 2025 ABCA 322In Reddy v Saroya, the Court of Appeal of Alberta held that an appellant's factum containing seven fabricated authorities — produced by a contractor using generative AI — was the signing lawyer's responsibility. It signalled personal costs; a later order (reported as 2026 ABCA 20, CAD $17,550) is said to be Canada's first personal-costs order for AI hallucinations.
2024-02-20Costs order
Zhang v Chen, 2024 BCSC 285The first reported Canadian case of AI-hallucinated citations: a Vancouver family lawyer cited two ChatGPT-invented cases in a notice of application, was ordered to pay costs personally, had her other files reviewed, and faced a Law Society of British Columbia investigation.
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