HDO v MDF
CA Alberta · Feb 17, 2026
- Jurisdiction
- international
- Court
- CA Alberta
- Record ID
- hdo-v-mdf-2026-02-17
- Observed outcome
- The application to restore the appeal was granted; the court issued a formal warning regarding the use of AI-generated legal citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Court of Appeal of Alberta issued a formal warning to a self-represented litigant after discovering that her court submissions included fabricated and misrepresented case law generated by artificial intelligence. The court did not impose sanctions in this instance but cautioned that future reliance on unverified AI-generated content could result in serious penalties.
Fabricated: Case Law | Several cited cases did not exist; provided links directed the court to a large language model platform webpage indicating the citations were fabricated by AI. || Misrepresented: Case Law | Other cited authorities were real but were relied on for propositions they did not support (irrelevant or misrepresented precedent).
Pro-se AI hallucinations in Alberta appellate filings drew warnings, not sanctions — threshold remains attorney conduct.
Failure modes and consequences
- Fabricated Case Law
- Misrepresented Precedent
- Pro Se
- Fake Citations
- Misrepresented Authority
- Family
- AI attribution
- Explicitly Recorded
- Recorded tool
- Generative artificial intelligence (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Application to restore an appeal and extend time to file the appeal record.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court identified the citations as hallucinations produced by generative artificial intelligence.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.