Lloyd’s Register Canada v. Munchang Choi
Federal Court of Canada · Jul 10, 2025
- Jurisdiction
- international
- Court
- Federal Court of Canada
- Record ID
- lloyds-register-canada-v-munchang-choi-2025-07-10
- Observed outcome
- The Motion Record was removed from the court file, and the Respondent was ordered to pay $500 CAD in costs to the Applicant.
- Known monetary consequence
- CA$500
Why this matter warrants attention
The Federal Court of Canada ordered the removal of a Motion Record from the court file and awarded $500 CAD in costs against a self-represented litigant who submitted fabricated case law generated by AI. The Court found the litigant failed to comply with the mandatory AI disclosure requirements and engaged in an abuse of process by citing non-existent authorities.
The Court reasoned that citing fake cases constitutes an abuse of process and a false statement to the court. It determined that the Respondent's failure to provide the mandatory AI declaration, combined with a history of similar misconduct and a lack of contrition, necessitated the removal of the Motion Record to preserve the integrity of the administration of justice.
Federal Court of Canada's AI Practice Direction requires an affirmative declaration; silence plus fabrication escalates to vexatious status.
Failure modes and consequences
- Pro Se
- Fake Citations
- Misrepresented Authority
- Administrative
- Trial
- Monetary
- AI attribution
- Admitted
- Recorded tool
- generative AI tools
- Known monetary consequence
- CA$500
- Procedural posture
- Order following a show-cause motion brought by the Applicant to remove a Motion Record from the court file due to the inclusion of fabricated case law.
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 Respondent admitted to using generative AI tools for drafting and research.
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
- Ensure strict compliance with the Federal Court of Canada’s AI Practice Direction by providing an affirmative declaration if AI tools are used in drafting.
- Independently verify the existence and content of every legal authority cited in court filings.
- Maintain a record of the research process to demonstrate due diligence in the event of a challenge to the accuracy of cited authorities.