KH (Re)
Alberta CJ · May 28, 2026
- Jurisdiction
- international
- Court
- Alberta CJ
- Record ID
- kh-re-2026-05-28
- Observed outcome
- The court dismissed the Director's application for a Permanent Guardianship Order and ordered the Mother's counsel to self-report the AI-misuse incident to the Law Society of Alberta.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Alberta Court of Justice ordered the Mother’s counsel to self-report to the Law Society of Alberta after the counsel admitted to including two AI-hallucinated, non-existent case citations in written closing submissions. The court found that the counsel failed to exercise necessary human oversight over work delegated to an assistant, violating professional standards for court submissions.
The court reasoned that the counsel's failure to verify AI-generated content violated the 2023 Alberta Courts' Notice on the use of large language models. The judge emphasized the lawyer's duty as an officer of the court to ensure accuracy, noting that the seriousness of the underlying child welfare matter necessitated a formal referral to the Law Society for professional conduct review.
This case illustrates the judiciary's enforcement of the 'human-in-the-loop' requirement for AI-assisted legal drafting. It serves as a precedent for professional accountability when counsel fails to verify AI-generated citations, reinforcing that delegation to assistants does not absolve lawyers of their duty of candor.
Failure modes and consequences
- Fake Citations
- Administrative
- Trial
- None Adjudicated
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- Adjudicated decision following a child welfare trial and a subsequent hearing regarding the misuse of generative AI in closing submissions.
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
Counsel admitted to using generative AI; tool name not specified.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all case law citations generated or assisted by AI tools.
- Establish supervisory workflows requiring senior counsel review of all AI-assisted drafts before filing.
- Ensure compliance with local court notices regarding the use of large language models in legal submissions.