Wang, Fengxi (Re)
Ontario SCJ · Dec 1, 2025
What happened in this matter?
The court identified multiple fabricated case citations in the litigant's submissions, which it attributed to the likely use of artificial intelligence. The court admonished the litigant for the waste of judicial resources caused by these non-existent authorities but declined to impose an immediate sanction, reserving the right to do so in the future.
- Why the court cared
- Fabricated: Case Law | Wang cited 'Royal Bank v. Humaira, 2019 ONCA 667' which the court could not locate on CanLII; court concluded it was a non-existent authority likely generated by AI. || Fabricated: Case Law | Wang cited 'Royal Bank v. Rehmani, 2017 ONCA 615' which the court could not verify and found the neutral citation did not match the stated style of cause. || Fabricated: Case Law | Wang cited 'Royal Bank v. St-Onge, 2001 SKCA 117' but the court was unable to locate that style of cause and concluded it was erroneous. || Fabricated: Case Law | Wang cited 'Re H.Y. Louie Co. Ltd., 2001 BCSC 556' for contingent guarantee principles but the court could not verify the citation on CanLII and found it inconsistent with the authorities it purported to rely on.
- Why it matters now
- Ontario SCJ admonishments for AI fabrications are stacking up in reported reasons — the public record compounds over time.
Why this matter is tracked
In a contested bankruptcy application, self-represented litigant Fengxi Wang submitted legal authorities to support his argument that the debt was not provable. The Ontario Superior Court of Justice found that these authorities, including 'Royal Bank v. Humaira, 2019 ONCA 667' and others, were non-existent and could not be verified on CanLII. The court concluded that Wang likely used artificial intelligence to generate these fabricated citations. While the court noted that the misuse of AI caused a waste of judicial resources and delayed the decision, it declined to impose a formal sanction at that time, noting that Wang had not yet had an opportunity to explain the source of the citations, though it reserved the right to impose sanctions later.
Ontario SCJ admonishments for AI fabrications are stacking up in reported reasons — the public record compounds over time.
Record details
What the record establishes about AI use
The court concluded the litigant likely used AI to generate the non-existent authorities.
Contested bankruptcy application heard on October 21 and November 10, 2025, resulting in a granted bankruptcy order.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Wang cited 'Royal Bank v. Humaira, 2019 ONCA 667' which the court could not locate on CanLII; court concluded it was a non-existent authority likely generated by AI.
- Fabricated: Case Law | Wang cited 'Royal Bank v. Rehmani, 2017 ONCA 615' which the court could not verify and found the neutral citation did not match the stated style of cause.
- Fabricated: Case Law | Wang cited 'Royal Bank v. St-Onge, 2001 SKCA 117' but the court was unable to locate that style of cause and concluded it was erroneous.
- Fabricated: Case Law | Wang cited 'Re H.Y. Louie Co. Ltd., 2001 BCSC 556' for contingent guarantee principles but the court could not verify the citation on CanLII and found it inconsistent with the authorities it purported to rely on.
Questions this record answers
- What happened in Wang, Fengxi (Re)?
- The court identified multiple fabricated case citations in the litigant's submissions, which it attributed to the likely use of artificial intelligence. The court admonished the litigant for the waste of judicial resources caused by these non-existent authorities but declined to impose an immediate sanction, reserving the right to do so in the future.
- Why does Wang, Fengxi (Re) matter for legal AI risk?
- Ontario SCJ admonishments for AI fabrications are stacking up in reported reasons — the public record compounds over time.
- What does the public record establish about Wang, Fengxi (Re)?
- 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 Wang, Fengxi (Re) 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
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