Court of Appeal of Québec Cites Courtready Research on AI-Hallucinated Case Law

The Court of Appeal of Québec has cited Courtready research in a judgment sanctioning a self-represented appellant who supported several grounds of appeal with four judgments that do not exist.

Québec City, seat of the courts of the province of Québec

On August 11, 2026, the Court of Appeal of Québec released its judgment in Droit de la famille — 261234, 2026 QCCA 1092. A self-represented appellant supported several grounds of appeal with two Supreme Court of Canada judgments and two Court of Appeal judgments that do not exist. He also attributed legal principles to those judgments and presented them as quotations. Those principles were fabricated too (para. 22).

The Court held that misleading a court by deliberately relying on non-existent decisions is a substantial breach in the conduct of the proceeding under art. 342 C.C.P. It found the conduct deliberate here, because the appellant knew the authorities were fictitious before he filed his memorandum (para. 25). It described that conduct as a serious breach that has become recurrent in Canadian law. For that proposition, the panel cited Courtready research published on CanLII (footnote 9).

The cited research is “The Rise of AI-Hallucinated Case Law in Canadian Courts and Tribunals,” 2026 CanLIIDocs 738, by Courtready.ca co-founder Tom Macintosh Zheng.

The figures the Court cited have moved since the research was published on April 14, 2026. As of August 16, 2026, Canadian courts and tribunals have flagged 239 decisions involving AI hallucinations or other forms of AI misuse. Of those, 223 involve fictitious citations, hallucinated propositions of law, or fabricated quotations.

The Court ordered the appellant to pay the respondent $1,000 in legal costs as compensation for the time she devoted to the matter and the work she performed, in addition to the costs of the appeal. Art. 340 C.C.P. ordinarily leaves each party in a family matter to bear its own legal costs. The judgment also quotes from the Chief Justice of Québec’s Notice Respecting the Use of Artificial Intelligence before the Court of Appeal, which places the responsibility for verifying AI-assisted research on the litigant (para. 23).

We are grateful to CanLII for keeping Canadian decisions publicly available.

Sources

The judgment is reported at 2026 QCCA 1092 and is available on CanLII. It is a family matter, and art. 16 C.C.P. prohibits disclosing information that would identify a party or a child whose interests are at stake, so no party is named here. Courtready’s database of AI hallucinations and other forms of AI misuse in Canadian courts and tribunals is updated regularly.