Quebec's appeal court ordered a self-represented litigant to pay $1,000 in costs for filing four ChatGPT-fabricated court decisions

Verification status: CHECKING (handed to the checker). A second genuinely independent newsroom — Law360 Canada (Cristin Schmitz, Aug. 18 2026) — now carries the $1,000 costs order and the ChatGPT-fabrication basis firsthand alongside the Canadian Press wire, lifting corroboration to court-origin two_independent, and the primary reasons are byte-tied to the Wayback Machine. Not verified from the war-room: only the checker’s audit grants the green badge, and the owner validates it.

The problem

This is an AI-governance honest-negative, not a deployment win: a court’s response to unverified generative-AI output filed as legal argument (source). In a family-law appeal over the division of assets following a divorce, a self-represented appellant filed a memorandum that “relies on two Supreme Court judgments and two Court judgments that do not exist” and that “ascribes to those decisions legal principles that he reproduces as quotations, even though those principles are no more real than the judgments themselves” (source). The Court noted the appellant was “not ill-equipped to deal with legal proceedings and legal argument” and “works as an IT consultant for his own firm” (source).

What was built

No system was built or deployed; the appellant used a general-purpose chatbot to research and draft his submissions (source). When questioned by the Court, “the appellant conceded that these authorities are the product of the artificial intelligence ChatGPT” (source). The Court recorded that the failure was not innocent: the appellant “discovered they did not exist during a consultation with counsel even before filing his memorandum, but he did not consider it necessary to amend his memorandum to remove the fabricated references and quotations before filing it, attributing this to an oversight on his part” (source). A Canadian Press wire carried by CBC News reports the same basis — “fake legal cases generated by ChatGPT” — and that the man learned the cases did not exist during a consultation with a lawyer but filed his arguments without removing them (source). Law360 Canada, reporting the case independently, likewise records the appellant’s “deliberate” citation “of ChatGPT-generated fake case law, including fictitious quotations” (source).

The outcome

The Court treated the conduct as a sanctionable breach, holding that “no one can assume that the result obtained is free from hallucinations produced by the engine used” (source). Citing non-existent decisions “whether generated by artificial intelligence or otherwise … amounts to a substantial breach in the conduct of the proceeding under art. 342 C.C.P.” (source). On costs, the Court held it would “reduce the amount of $5,000 claimed by the respondent and order the appellant to pay her $1,000 in legal costs as compensation for the time devoted to the matter and the work performed, in addition to bearing the costs of the appeal” (source). The dispositive order “CONDEMNS A. P. to pay the amount of $1,000 to S. K.” within 30 days of the appeal judgment (source). The Court dismissed the principal appeal, dismissed the application for leave to present new evidence, and allowed the incidental appeal in part, all with costs against the appellant (source). CBC’s report independently confirms the $1,000 costs figure and the ChatGPT basis (source), and Law360 Canada reports firsthand that “Quebec’s top court has ordered a self-represented family law appellant to pay $1,000 to his ex-wife plus her legal costs on the appeal” (source).

Why this is at checking, not yet green

Court-origin, and now carried firsthand by two genuinely independent newsrooms: the $1,000 costs order, the ChatGPT concession and the four fabricated judgments are all in the Court of Appeal’s own signed reasons (Tier 1), and both a Canadian Press wire (source) and Law360 Canada’s independent bylined report (source) corroborate the $1,000 and the ChatGPT basis firsthand. Weak-source honesty: the two independent secondaries carry different weight — the Canadian Press wire (CBC News and Global News run the same CP copy, counting as one independent secondary) prints only the facts common to a wire summary, while the Law360 Canada corroboration rests on its public headline and meta description because its article body is paywalled; neither prints the 2026 QCCA 1092 citation, the docket or art. 342 C.C.P., which rest on the Court’s own reasons (source). The green badge is the checker’s call against the public record, then the owner’s to validate — never the litigants confirming their own matter.

Conflation guard

Do not merge this with Specter Aviation Limited c. Laprade, 2025 QCCS 3521 — a separate Quebec Superior Court decision that fined a different self-represented litigant $5,000 for ChatGPT-fabricated citations, and which is cited as a footnote inside these reasons (source). The $5,000 in this story is the amount the respondent claimed and the Court reduced, not a sanction; the operative figure is the $1,000 the Quebec Court of Appeal ordered (source).

How this was verified

Method: the critical facts — the $1,000 costs order, the “product of the artificial intelligence ChatGPT” concession, the four non-existent judgments, the “substantial breach” art. 342 C.C.P. framing and the Aug. 11, 2026 disposition — were quoted verbatim from the Quebec Court of Appeal’s own signed reasons (2026 QCCA 1092, court-origin Tier 1), re-fetched this session from the Damien Charlotin tracker’s S3 mirror and cross-checked against two independent newsrooms: a Canadian Press wire carried by CBC News (Tier 2) and Law360 Canada’s bylined report (Cristin Schmitz, Aug. 18 2026, Tier 2). The byte-tie is closed: the Internet Archive outage has cleared and the S3 mirror is captured at web.archive.org (2026-08-17 snapshot) with a CDX SHA-1 digest of FAMRHEZE3D6EJ7M5RQZ4HJK3GTATEHUI, byte-identical to the local PDF. Checked 2026-08-21.

Sources

1. Tier 1 — Quebec Court of Appeal (Cour d’appel du Québec) · A. P. v. S. K., 2026 QCCA 1092 (signed reasons; Damien Charlotin AI-litigation tracker S3 mirror; byte-tied to Wayback Machine 2026-08-17, CDX SHA-1 FAMRHEZE3D6EJ7M5RQZ4HJK3GTATEHUI) · 2026-08-11 · https://www.damiencharlotin.com/documents/2830/AP_v._SK_Canada_11_August_2026.pdf
2. Tier 2 — CBC News (carrying a Canadian Press wire) · “Quebec man ordered to pay $1K over use of fake AI-generated court cases” · 2026-08-16 · https://www.cbc.ca/news/canada/montreal/quebec-fine-ai-court-cases-9.7309184
3. Tier 2 — Law360 Canada (LexisNexis Canada), Cristin Schmitz · “Quebec Appeal Court dings family self-rep $1K plus costs for ‘deliberate’ use of bogus ChatGPT cases” (bylined original reporting, distinct from the CP wire; article body paywalled, public headline + meta description carry the $1,000 and ChatGPT-fabrication basis firsthand) · 2026-08-18 · https://www.law360.ca/ca/estates/articles/2515051

Related case files

• Nova Scotia’s appeal court awarded $20,000 in indemnity costs over AI-fabricated transcripts and a forged transcriber certificate — the closest Canadian appellate parallel
• An Ontario Divisional Court ordered $10,000 in costs for improper AI use in a factum — another Canadian court pricing the cost of unverified AI submissions
• A Federal Court ordered an NGO to pay $500 CAD after 45 of 62 citations were AI-hallucinated — the same pattern of fabricated authorities, a lighter costs award
• The Washington federal LeDoux v. Outliers Thesis $3,000 Rule 11 sanction for ChatGPT/Claude-fabricated citations — the U.S. counterpart to this ChatGPT-fabrication cost order