Alana Kotler v Ontario Secondary School Teachers’ Federation
Ontario Labour Relations Board · Aug 29, 2025
What happened in this matter?
The Ontario Labour Relations Board dismissed the application for failing to establish a prima facie case. The Board explicitly rejected the applicant's reliance on fifteen unlocatable case citations, noting that the applicant failed to provide copies when requested and that the cited authorities were either non-existent or misrepresented.
- Why the court cared
- The Board reasoned that it cannot consider cases that do not exist or cannot be located. It further determined that the union's duty of fair representation under section 74 does not extend to internal union affairs or processes, and that the applicant failed to provide any evidence of collusion between the union and the school board.
- Why it matters now
- Fifteen-plus unlocatable cites got the application dismissed; a single bad cite poisons the whole brief in labour tribunals.
Why this matter is tracked
The applicant, Alana Kotler, filed an application under section 96 of the Labour Relations Act alleging a breach of the duty of fair representation. The Ontario Labour Relations Board dismissed the application, finding it failed to establish a prima facie case. The Board noted that the applicant had already received the requested representation for her internal complaint and that the union's statutory duty did not extend to the Human Rights Tribunal of Ontario. Furthermore, the applicant relied on fifteen case citations that the Board and the responding party could not locate. When challenged, the applicant acknowledged potential citation errors but refused to provide copies. The Board held that it cannot consider non-existent or unlocatable authorities and dismissed the application.
Fifteen-plus unlocatable cites got the application dismissed; a single bad cite poisons the whole brief in labour tribunals.
Record details
What the record establishes about AI use
The responding party requested confirmation if the cases were hallucinated via AI.
The Board dismissed the application without a hearing or consultation pursuant to Rule 39.1 of the Board’s Rules of Procedure, finding it failed to make out a prima facie case.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
15 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited.
- Misrepresented: Case Law | Applicant relied on Micheal Lind v. International Alliance...; the Board located a decision with the same locator but it is a brief procedural decision that does not support the proposition relied upon by the applicant (misrepresented).
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited.
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited.
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited.
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited.
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited (Latreille appears again in another citation form).
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited (Hargrave variant cited by applicant not located).
Show 7 additional discrepancies
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited.
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited (external tribunal decisions cited but not located).
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited (external tribunal decision cited but not located).
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited.
- Fabricated: Case Law | Case cited by applicant could not be located by the Board or OSSTF as cited (board could not locate the Millen decision as cited).
- Fabricated: Case Law | Unreported decision cited by applicant that the Board could not locate as cited.
- Fabricated: Case Law | Recent external decision cited by applicant that the Board and OSSTF could not locate as cited.
Questions this record answers
- What happened in Alana Kotler v Ontario Secondary School Teachers’ Federation?
- The Ontario Labour Relations Board dismissed the application for failing to establish a prima facie case. The Board explicitly rejected the applicant's reliance on fifteen unlocatable case citations, noting that the applicant failed to provide copies when requested and that the cited authorities were either non-existent or misrepresented.
- Why does Alana Kotler v Ontario Secondary School Teachers’ Federation matter for legal AI risk?
- Fifteen-plus unlocatable cites got the application dismissed; a single bad cite poisons the whole brief in labour tribunals.
- What does the public record establish about Alana Kotler v Ontario Secondary School Teachers’ Federation?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Alana Kotler v Ontario Secondary School Teachers’ Federation summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
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