Incident Tracker

Ko v. Li, 2025 ONSC 2965; 2025 ONSC 6785

referral

In Ontario, lawyer Jisuh Lee filed a ChatGPT-fabricated factum in Ko v. Li and initially avoided contempt on conditions (2025 ONSC 2965). After she admitted lying about authorship, Justice Myers reopened the matter (2025 ONSC 6785), referred a criminal-contempt prosecution to Ontario's Attorney General, and the Law Society of Ontario opened an investigation.

Date of decision/order

2025-12-04

Court

Ontario Superior Court of Justice

Jurisdiction

CANADA

AI tool

ChatGPT

Conduct

Applicant's counsel Jisuh Lee filed a factum citing fabricated cases hallucinated by ChatGPT and relied on them orally. An initial contempt was treated as purged after she blamed staff (2025 ONSC 2965, 20 May 2025); Lee then admitted, in a 30 Sept 2025 letter, that she had drafted the factum herself and had lied about it out of fear and embarrassment — a fresh deception of the court (2025 ONSC 6785, 4 Dec 2025).

Consequence

See outcome

Regulatory outcome

Law Society of Ontario: The Law Society of Ontario is investigating Lee's conduct (file CAS-165781-ZOC5S2) and attended the December 2025 case conference as an observer; no disposition yet. Separately, Justice Myers issued a fresh show-cause for criminal contempt and referred carriage to the Attorney General of Ontario; the Crown took carriage and an amicus curiae (Dean Embry) was appointed. No finding of contempt yet. (2025-12-04)

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