Makongo c. Montpetit
Québec · Mar 3, 2026
What happened in this matter?
The Court of Québec sanctioned pro se litigants for submitting fabricated and misrepresented case law generated by AI. Finding this conduct a significant procedural breach that wasted judicial and party resources, the Court ordered the litigants to pay 800 CAD in compensation to the respondent under Article 342 of the Code of Civil Procedure.
- Why the court cared
- Fabricated: Case Law | Citation could not be located in legal databases; tribunal treated the reference as fictitious. || Misrepresented: Case Law | Citation provided (QCCA) was introuvable; an existing Supreme Court decision on the same name addresses unrelated issues — principle misattributed. || Misrepresented: Case Law | Named neutral citation did not correspond to the case cited (mis-citation/misattribution). || Misrepresented: Case Law | Real criminal-law decision cited and used to support unrelated civil procedural principles (misattribution/irrelevant authority). || Misrepresented: Case Law | Neutral/reference citation corresponded to a different decision (mis-citation); the named decision did not support the principle invoked.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in Québec, with the listed outcome: Monetary Sanction.
Why this matter is tracked
In this civil matter, the Court of Québec addressed a request by pro se litigants to annul an execution of judgment. During proceedings, the litigants submitted a memorandum containing multiple fabricated or misrepresented case law citations. Despite the Court providing multiple opportunities for the litigants to verify or produce the cited decisions, they persisted in maintaining the validity of the fictitious references. The Court determined that the litigants' conduct, including the use of AI-generated content and subsequent refusal to acknowledge the errors, constituted a significant procedural breach under Article 342 of the Code of Civil Procedure. Consequently, the Court rejected the litigants' motion and ordered them to pay 800 CAD to the respondent as compensation for the time and resources wasted due to the procedural misconduct.
This record documents a Pro Se Litigant filing issue in Québec, with the listed outcome: Monetary Sanction.
Record details
What the record establishes about AI use
The litigants initially conceded AI use but later retracted the statement.
Judgment on a motion for stay and annulment of an execution of judgment, including a determination on procedural sanctions for the submission of fabricated legal authorities.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
5 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Citation could not be located in legal databases; tribunal treated the reference as fictitious.
- Misrepresented: Case Law | Citation provided (QCCA) was introuvable; an existing Supreme Court decision on the same name addresses unrelated issues — principle misattributed.
- Misrepresented: Case Law | Named neutral citation did not correspond to the case cited (mis-citation/misattribution).
- Misrepresented: Case Law | Real criminal-law decision cited and used to support unrelated civil procedural principles (misattribution/irrelevant authority).
- Misrepresented: Case Law | Neutral/reference citation corresponded to a different decision (mis-citation); the named decision did not support the principle invoked.
Questions this record answers
- What happened in Makongo c. Montpetit?
- The Court of Québec sanctioned pro se litigants for submitting fabricated and misrepresented case law generated by AI. Finding this conduct a significant procedural breach that wasted judicial and party resources, the Court ordered the litigants to pay 800 CAD in compensation to the respondent under Article 342 of the Code of Civil Procedure.
- Why does Makongo c. Montpetit matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in Québec, with the listed outcome: Monetary Sanction.
- What does the public record establish about Makongo c. Montpetit?
- 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 Makongo c. Montpetit 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.