Description: In Ko v. Li, 2025 ONSC 2766, the Ontario Superior Court of Justice identified multiple inaccurate or nonexistent case citations in a factum submitted by counsel for the applicant. Justice FL Myers questioned whether generative AI was used in drafting the document, noting the cited cases were either irrelevant, misrepresented, or did not exist. The court ordered the lawyer to show cause why she should not be cited for contempt, citing duties of accuracy and technological competence.
Editor Notes: Timeline note: April 25, 2025 is the date the factum containing allegedly AI-generated citations was signed and submitted. May 1 marks the court hearing where the judge identified and questioned the suspect citations. May 6 is the date of the written decision ordering counsel to show cause. Clarification regarding the AI system and deployer: Justice Myers writes, "I asked Ms. Lee if her factum was prepared by artificial intelligence - like ChatGPT. She told me that her office does not usually do so but that she would have to check with her clerk. Ms. Lee was unable to provide me with citations to the cases cited in her factum or to provide me with copies of the cases from the printed papers she was using to make her submissions." The incident is tagged with "Unspecified large language model" as the AI system, since "like ChatGPT" is used illustratively, not as a definitive attribution. While Jisuh Lee is tagged as the deployer, her recorded answer suggests the possibility that someone else may have deployed the large language model to generate the citations.
Entities
View all entitiesAlleged: Unspecified large language mode developer developed an AI system deployed by Jisuh Lee, which harmed Jisuh Lee , Hanna Ko , Ontario Superior Court of Justice and Legal integrity.
Alleged implicated AI system: Unspecified large language model
Incident Stats
Incident ID
1099
Report Count
2
Incident Date
2025-04-25
Editors
Daniel Atherton
Incident Reports
Reports Timeline
CITATION: Ko v. Li, 2025 ONSC 2766
COURT FILE NO.: CV-25-00736891-00ES
DATE: 20250506
ONTARIO SUPERIOR COURT OF JUSTICE
RE: Hanna Ko,
Applicant
-and-
Hai Chun Li and Zhou Hang Li, in their capacity as the Estate Trustees for the …
In what has become a distressingly familiar pattern in courtrooms across America, two more cases have emerged of lawyers submitting briefs containing non-existent legal citations generated by AI tools.
At this point, one wonders if the lega…
Variants
A "variant" is an AI incident similar to a known case—it has the same causes, harms, and AI system. Instead of listing it separately, we group it under the first reported incident. Unlike other incidents, variants do not need to have been reported outside the AIID. Learn more from the research paper.
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