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Incident Tracker / Canada

A.P. v. S.K. (Droit de la famille, 261234), 2026 QCCA 1092

·Quebec Court of Appeal·CASanctions

The 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.

Court
Quebec Court of Appeal
Date
2026-08-11
Who used the AI
Litigant in person
AI tool
ChatGPT (conceded by the appellant)
Conduct
A self-represented appellant's memorandum in a family-law appeal cited two nonexistent Supreme Court of Canada judgments and two nonexistent lower-court judgments, with invented quotations. He conceded they were ChatGPT fabrications; the respondent had sought CAD 5,000.
Outcome
Sanctions
Penalty
CA$1,000
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-03

What was fabricated or misused

  • two Supreme Court judgments and two Court judgments that do not exist; the Court of Appeal did not name them
  • legal principles reproduced as quotations from those four fictitious decisions

What the court said

“In support of several of his grounds of appeal, the appellant relies on two Supreme Court judgments and two Court judgments that do not exist.”
Quebec Court of Appeal, [22]
“The appellant conceded that these authorities are the product of the artificial intelligence ChatGPT.”
Quebec Court of Appeal, [22]
“However, no one can assume that the result obtained is free from hallucinations produced by the engine used.”
Quebec Court of Appeal, [24]
“He chose to file a memorandm tainted by references to non-existent decisions and fabricated quotations, and to remain silent about the matter until questioned about it by members of the Court.”
Quebec Court of Appeal, [30]

Timeline

  1. Superior Court granted the parties' divorce.
  2. Superior Court rendered the corollary-relief judgment under appeal.
  3. Court of Appeal heard the appeal.
  4. Court dismissed the principal appeal and ordered A.P. to pay S.K. $1,000.

Why this case matters

A.P. v. S.K. is a Canadian self-represented family-law record like Arbuckle v Tanner, but the misuse was legal authority rather than the appeal record. It is also more direct than Harber v HMRC: the appellant conceded ChatGPT generated the non-existent cases and had learned that before filing, yet left them in the memorandum. The Quebec Court of Appeal used article 342 C.C.P. to compensate an unrepresented respondent for time and work, showing that family-cost rules did not block a targeted award for AI-fabricated authorities.

Practice note

If a litigant uses ChatGPT for appeal research, every case must be checked against court websites or recognized legal databases before the memorandum is filed. If counsel or another checker discovers a case does not exist, the filing must be amended before submission, not simply omitted from the book of authorities.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

Similar incidents on the record

  • Arbuckle v. Tanner, 2026 NSCA 622026-08-12 · Nova Scotia Court of Appeal (chambers) · Costs orderThe 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 te…
  • Specter Aviation Limited c. Laprade, 2025 QCCS 35212025-10-01 · Cour supérieure du Québec (Quebec Superior Court) · FineIn Quebec, the Superior Court ordered self-represented litigant Jean Laprade to pay CAD $5,000 under article 342 of the Code of Civil Procedure after his AI-assisted contestation contained eight instances of fabricated…
  • Ahmed v. Canada (Citizenship and Immigration), 2026 FC 1202 (IMM-3886-26)2026-09-28 · Federal Court (Canada) · DismissalIn Canada, the Federal Court refused a late filing in a refugee judicial review because the proposed memorandum cited five cases that could not be found and misstated others. Justice Lafrenière inferred unchecked AI use…
  • Asiedu v. Eastlund, Nos. A25-2106, A26-0532 (Minn. Ct. App.)2026-09-08 · Minnesota Court of Appeals · SanctionsIn Minnesota Court of Appeals, self-represented litigant Michael Asiedu admitted he used artificial intelligence for research and did not verify citations. The district court found the filings cited non-existent cases o…

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “A.P. v. S.K. (Droit de la famille, 261234), 2026 QCCA 1092”, safelegalai.com/tracker/ap-v-sk-qcca-1092 (accessed 2026-10-07). Data: CC BY 4.0.

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