Erin Gray v Attorney General of Canada
Federal Court · Mar 5, 2026
What happened in this matter?
The court identified that the pro se applicant included two fabricated case citations in her memorandum, which she admitted were generated by an AI tool. The court noted this violated the Federal Court Practice Direction on the use of AI, though it did not impose specific sanctions for the AI usage itself.
- Why the court cared
- Fabricated: Case Law | One of the Applicant's memorandum citations did not exist; the Court found it to be a fabricated case citation produced by AI and described the jurisprudence as hallucinated. || Fabricated: Case Law | A second memorandum citation was likewise non-existent; the Court identified it as another fabricated case citation resulting from the Applicant's use of AI.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in Federal Court, with the listed outcome: no adjudicated outcome recorded.
Why this matter is tracked
In a judicial review of a Canada Revenue Agency decision regarding CERB eligibility, the pro se applicant submitted a memorandum containing five case citations, two of which were non-existent. During the hearing, the applicant admitted to using an artificial intelligence application to assist in drafting her materials. The Federal Court noted that the applicant failed to comply with the Federal Court Practice Direction regarding the use of AI in court proceedings. The Court characterized the inclusion of the fabricated citations as 'hallucinated jurisprudence' and emphasized that the Practice Direction exists to protect the integrity of judicial proceedings and safeguard public confidence in the justice system. The underlying application for judicial review was ultimately dismissed on its merits.
This record documents a Pro Se Litigant filing issue in Federal Court, with the listed outcome: no adjudicated outcome recorded.
Record details
What the record establishes about AI use
The applicant admitted to using an unidentified AI application.
Judicial review of a Canada Revenue Agency decision denying CERB eligibility, dismissed by the Federal Court.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | One of the Applicant's memorandum citations did not exist; the Court found it to be a fabricated case citation produced by AI and described the jurisprudence as hallucinated.
- Fabricated: Case Law | A second memorandum citation was likewise non-existent; the Court identified it as another fabricated case citation resulting from the Applicant's use of AI.
Questions this record answers
- What happened in Erin Gray v Attorney General of Canada?
- The court identified that the pro se applicant included two fabricated case citations in her memorandum, which she admitted were generated by an AI tool. The court noted this violated the Federal Court Practice Direction on the use of AI, though it did not impose specific sanctions for the AI usage itself.
- Why does Erin Gray v Attorney General of Canada matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in Federal Court, with the listed outcome: no adjudicated outcome recorded.
- What does the public record establish about Erin Gray v Attorney General of Canada?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Erin Gray v Attorney General of Canada 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.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.