AI-Fabricated Legal Citations Sanctioned Across Canadian Courts

AI-generated fabricated legal citations have been submitted to courts in all four major Canadian jurisdictions — British Columbia, Ontario, Quebec, and Federal Court — by both lawyers and self-represented litigants, establishing a cross-jurisdictional pattern.

Zhang v. Chen (2024 BCSC 285) — the first reported Canadian case. Lawyer Ke cited two non-existent cases generated by ChatGPT in a family law matter. The BC Supreme Court ordered the lawyer to personally bear costs and review all files for AI-generated citations (Supreme Court of British Columbia (via CanLII), 2024).

Specter Aviation v. Laprade (2025 QCCS 3521) — A 74-year-old self-represented litigant in Quebec submitted legal arguments containing eight instances of fabricated case law. The Quebec Superior Court imposed the first financial sanction in Quebec for AI-hallucinated legal content — a $5,000 fine under article 342 of the Code of Civil Procedure for "significant breach" of procedural obligations (Quebec Superior Court (via CanLII), 2025; Global News, 2025; Gowling WLG, 2025; McMillan LLP, 2025). The litigant apologized to the court.

Ko v. Li (2025 ONSC 2766/2965/6785) — A lawyer in an Ontario estates/family law proceeding submitted a factum citing non-existent or irrelevant cases likely generated by AI. Justice Myers ordered counsel to show cause for contempt. Counsel admitted error and apologized; contempt proceedings were discontinued. Justice Myers noted counsel had failed to include the certification required by Ontario Rule 4.06.1(2.1) — enacted in 2024 specifically to address AI-hallucinated citations — which requires lawyers to certify the authenticity of authorities cited in submissions (Ontario Superior Court of Justice (via CanLII), 2025).

Hussein v. Canada (2025 FC 1060) — Immigration counsel used Visto.ai, an AI legal research tool, and submitted two non-existent cases to the Federal Court. The court found that the failure to disclose AI use in preparing submissions "amounts to an attempt to mislead the Court" (Federal Court (via CanLII), 2025) and in a subsequent costs decision (2025 FC 1138), awarded special costs against counsel personally.

The cases highlight a tension between access to justice and judicial integrity. Self-represented litigants increasingly turn to AI tools for legal assistance because they cannot afford lawyers. These tools generate confident, plausible-sounding legal analysis that non-experts cannot easily verify. At the same time, purpose-built legal AI tools like Visto.ai — which users might reasonably expect to be more reliable than general-purpose chatbots — also produce fabricated citations (Federal Court (via CanLII), 2025), indicating that the confabulation problem is structural to current generative AI, not limited to consumer chatbots.

Ontario's Rule 4.06.1(2.1), enacted in 2024, is the first Canadian procedural rule specifically addressing AI-hallucinated citations (Ontario Superior Court of Justice (via CanLII), 2025). Other jurisdictions have addressed the issue through case-by-case sanctions but have not yet implemented comparable systematic safeguards.