Why this matters now

AI that invents case law is getting lawyers sanctioned personally. Now the regulators have started too.

This isn't a cautionary hypothetical. In under three years, courts in British Columbia, Alberta, Saskatchewan, Ontario, Nova Scotia and the Federal Court have caught fabricated, often AI-generated, authorities in filings. The consequences have climbed from a warning, to costs against the lawyer personally, to solicitor-client costs, to a contempt show-cause order, and in July 2026 to a six-month suspension by a law society tribunal, for a lawyer who relied on a factum prepared by AI and then misled the court about her use of AI. It's on the record, and it cuts both ways: your citations can be fabricated, and so can the other side's.

The consequences are real, and they land on whoever signs the document.

Reddy v Saroya

An appeal factum drafted by a contractor using a large language model: "… nearly half of the cases listed in the table of authorities were non-existent." Lead counsel was ordered to pay $17,550 plus GST in costs, personally. That was consistent, the Court held, with the principle that "the lawyer whose name appears on the filed document bears ultimate responsibility for the material’s form and contents".

Ko v Li → Law Society of Ontario v Lee

A factum built on hallucinated cases; counsel was ordered to show cause on contempt. The show-cause was withdrawn on her undertaking to take professional-development courses and not to bill the client for the tainted motion. Fourteen months later the discipline tribunal found that she had failed to meet the standard of a competent lawyer and had "knowingly deceived the court on three occasions" about her use of AI, and suspended her for six months. By then Justice Myers had "referred carriage of a contempt of court proceeding to the Attorney General".

National Indigenous Fisheries Institute v Canada
2026 FC 382 · Federal Court

Counsel filed four decisions that "simply do not exist". The Court ordered costs on a solicitor-client basis, payable jointly and severally by the applicant and by its counsel personally, and said those costs were "not solely related to the undisclosed use of AI and the hallucinated cases".

Kapahi Real Estate v Elite Real Estate Club of Toronto
2026 ONSC 1438 · the next generation

The cases were real and the citations correct. The quotations attributed to them were not. "But then counsel added quotations from the cases. The quotations do not exist in the cases. The quotations are fake." Counsel denied using AI, and the Court made no finding that he had. Either way, checking that a case exists is no longer enough.

Zhang v Chen
2024 BCSC 285 · the one that started it

Opposing counsel caught the fabrications. Citing fake cases is "an abuse of process and is tantamount to making a false statement to the court." The additional expense was ordered borne personally by the lawyer.

T.B. v K.M.
2025 SKKB 176 · Saskatchewan K.B.

A self-represented litigant's brief of law cited cases that "do not exist or do not exist by the name, nor do they represent the principles K.M. suggests they do." The successful party was denied his costs anyway: "Fabricating law is unacceptable…"

And it isn't slowing down.

Haddadi v Soleimani · 2026 ONSC 3920: a cited rule that doesn't exist, "Rule 61.09(1)(d) does not exist." Hussein v Canada · 2025 FC 1060 at para 41: "…an attempt to mislead the Court and to conceal the reliance…"; 2025 FC 1138: costs against counsel personally Djatsa v Canada · 2026 FC 729: every case cited was fictitious; the record was struck from the court file DJ v SN · 2025 ABCA 383: three non-existent authorities, $500 costs, and a warning of "more substantial penalties" Krivaia v Hungerford · 2026 BCSC 408: "…their failure to check and independently verify the authenticity of their legal authorities is a serious oversight." Wu v Murray · 2025 BCCA 365, a registrar's ruling: two false cases on a central point; costs Lloyd's Register Canada Ltd v Choi · 2025 FC 1233: motion record removed from the file; $500 costs Mazac v Muise · 2026 NSSC 138: Nova Scotia

And the rules have caught up.

Ontario

Since 2024, a factum must carry a signed statement certifying that the signer is satisfied as to the authenticity of every authority cited in it.

Federal Court

Content created or generated by AI in materials prepared for litigation and submitted to the Court must be declared. Failing to declare it has itself drawn sanctions.

Alberta

A tri-court notice directs parties to rely on authoritative sources for case law, and the Court of Appeal, in Reddy v Saroya, has warned that those who fail to comply "should not expect leniency".

B.C. & Nova Scotia

Filing directives put responsibility for the authenticity and accuracy of everything filed on the person who files it, counsel and self-represented alike.

Saskatchewan

Since January 1, 2026, a Court of King's Bench practice directive (GA-PD #12) requires every legal reference produced with AI to be independently verified against authoritative sources, and tells lawyers that blind reliance on AI is inconsistent with professional competence.

The duty is yours.

Read across these decisions and the through-line is unmistakable. As the Ontario Superior Court put it in Ko v Li, 2025 ONSC 2965 at paras 21-22, "…the proverbial buck stops with counsel", and "Counsel may not mis-state or misrepresent the law to the court whether by way of AI hallucinations or by any other means." Nor is the duty counsel's alone. As the same court put it in Halton (Regional Municipality) v Rewa et al., 2025 ONSC 4503 at para 53: "Every person who submits authorities to the court has an obligation to ensure that those authorities exist and stand for the propositions for which they are advanced." Good faith, an apology, a contractor, a "trusted" tool: these have mitigated the sanction. Not one of them has erased it.

Every brief you sign, you certify. The obligation to verify that each authority exists, says what you claim, and is quoted accurately rests with the person who files it, not with the tool. WarmLoop does the mechanical first pass and shows you what it found, so your own check starts from the evidence instead of from scratch.

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