A June 2026 costs decision of the Law Society Tribunal of Ontario cites Courtready research to describe how often fictitious, AI-generated citations are reaching Canadian courts and tribunals.

On June 12, 2026, the Law Society Tribunal released a decision on the costs of two motions, reported at 2026 ONLSTH 112. A party had filed motion materials that cited cases which do not exist, along with real cases cited for propositions they do not support. The Tribunal ordered that party to pay costs of $31,150.

In its reasons, the Tribunal noted that this was the first time hallucinated authorities had appeared before it, and that the problem is not new to Canadian law. To describe the scale of the problem, the panel cited Courtready research published on CanLII. It recorded that the number of cases reported on CanLII in which a court or tribunal identified a fictitious citation rose from seven in 2024 to 86 in 2025, with a further 39 in the first quarter of 2026 (footnote 14).

The cited research is “The Rise of AI-Hallucinated Case Law in Canadian Courts and Tribunals,” 2026 CanLIIDocs 738, by Courtready co-founder Tom Macintosh Zheng. The decision notes that 24 of those 132 reported cases involved a represented party.

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