AI-Hallucinated 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 Chong 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.

Specter Aviation v. Laprade (2025 QCCS 3521) — Jean Laprade, 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 Canada for AI-hallucinated legal content — a $5,000 fine under article 342 of the Code of Civil Procedure for “substantial breach” of procedural obligations. Laprade apologized but told the court he would not have been able to defend himself without AI assistance.

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. The case prompted Ontario Rule 4.06.1(2.1), requiring lawyers to certify the authenticity of authorities cited in submissions.

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” and awarded costs against counsel.

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, indicating that the confabulation problem is structural to current generative AI, not limited to consumer chatbots.

Ontario’s introduction of Rule 4.06.1(2.1) represents the first Canadian procedural rule specifically responding to AI-hallucinated citations. Other jurisdictions have addressed the issue through case-by-case sanctions but have not yet implemented systematic safeguards.