Ko v. Li
Ontario SCJ · May 28, 2025
- Jurisdiction
- international
- Court
- Ontario SCJ
- Record ID
- ko-v-li-2025-05-28
- Observed outcome
- Show cause order dismissed on condition of mandatory Continuing Professional Development and a waiver of legal fees for the defective work.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court dismissed the contempt show cause proceeding against counsel after she admitted to filing AI-hallucinated case law. The judge declined to impose a fine, finding that the public shaming and counsel's remedial commitments—including mandatory Continuing Professional Development and a waiver of fees for the defective work—sufficiently addressed the court's concerns regarding professional conduct and the administration of justice.
The court reasoned that the goals of contempt proceedings—maintaining court dignity, denouncing misconduct, and deterrence—were already met through the public nature of the proceedings and counsel's forthright admission, apology, and commitment to remedial training. The court noted that Canadian courts have different regulatory roles compared to US courts regarding lawyer discipline and that the professional consequences already incurred by counsel were sufficient.
Counsel escaped fine only by agreeing to CPD and forgoing billing; ChatGPT hallucinations trigger mandatory training orders.
Failure modes and consequences
- Fake Citations
- Other
- Trial
- Monetary
- Case Dismissed
- Professional
- AI attribution
- Admitted
- Recorded tool
- ChatGPT
- Known monetary consequence
- Not recorded
- Procedural posture
- Show cause proceeding for contempt of court initiated by the Ontario Superior Court of Justice following the submission of a factum containing fabricated legal authorities.
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 using ChatGPT for the factum.
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
- Independently verify every legal authority cited in court filings using reliable databases like CanLII or Westlaw.
- Include mandatory certifications regarding the authenticity of cited precedents as required by local procedural rules.
- Implement internal protocols to ensure no AI-generated content is filed without rigorous manual review.
- Avoid delegating legal research to tools that cannot be personally controlled or verified.