X.L. v. Z.L. et al
Ontario SCJ · Oct 16, 2025
What happened in this matter?
The Ontario Superior Court of Justice identified that respondents used AI to generate legal submissions containing fabricated and misrepresented case law. The court disregarded these authorities, noting that the citations were either non-existent, hyperlinked to unrelated cases, or misapplied to the legal propositions advanced by the respondents.
- Why the court cared
- The court observed that the respondents' submissions contained citations that were either non-existent, hyperlinked to unrelated cases, or misapplied to the legal propositions, leading the court to conclude the submissions were AI-generated and unreliable.
- Why it matters now
- When hyperlinks point to unrelated cases, the court infers AI drafting and awards costs.
Why this matter is tracked
In a family law proceeding, the court identified that the respondents, Man Yee Shek and Chi Wo (Brian) Yip, submitted written and oral closing arguments containing numerous fabricated or misrepresented legal authorities. The court noted that several citations led to error pages, unrelated cases, or cases that did not support the propositions advanced. The presiding judge, Jarvis J., explicitly stated that these submissions were generated using artificial intelligence. Consequently, the court disregarded the authorities submitted by these parties. The court's decision focused on the substantive equalization of property and family law issues, while noting the serious concern regarding the use of AI to present unreliable legal research to the court.
When hyperlinks point to unrelated cases, the court infers AI drafting and awards costs.
Record details
What the record establishes about AI use
The court explicitly identified the use of artificial intelligence.
Final decision following a multi-day trial and closing submissions.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
8 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Citation to Gowling Lafleur Henderson LLP v. Shorter, 2011 ONSC 5840 could not be located (hyperlink led to an error); court treated it as AI-generated.
- Misrepresented: Case Law | Duggan v. Durham Region Law Association (2022 ONCA 216) was cited but hyperlinks directed to a different case and the citation/report could not be relied upon for the proposition advanced.
- Misrepresented: Case Law | Indalex Ltd., Re (2013 SCC 6) was cited for an unrelated proposition (pension administration case) and did not support the legal point advanced by the respondents.
- Misrepresented: Case Law | Ontario Inc. v. Ranch Heating and Air Conditioning (Barrie) Limited (2012 ONCA 182) was cited for a point about concealing/diverting assets but the case concerns negligence; citation misapplied.
- Misrepresented: Case Law | Ontario (Attorney General) v. Trinity Bible Chapel (2023 ONCA 134) was cited for fraudulent conveyance principles though it is a Charter/Covid-regulation case; citation misapplied.
- Misrepresented: Case Law | Ms. Shek cited Bank of Montreal v. Wilder for a proposition about fraudulent intent; the hyperlink led to Schuldt v. The Queen and the cited proposition was unsupported.
- Misrepresented: Case Law | Reference to Royal Bank of Canada v. North American Life Assurance Co. was hyperlinked to Gordon v. Goertz and did not support the proposition cited by the respondent.
- Fabricated: Case Law | Pinto v. BMO Trust Company (2017 ONCA 120) was cited but the case/report could not be located on reporting services; treated as an AI hallucination.
Questions this record answers
- What happened in X.L. v. Z.L. et al?
- The Ontario Superior Court of Justice identified that respondents used AI to generate legal submissions containing fabricated and misrepresented case law. The court disregarded these authorities, noting that the citations were either non-existent, hyperlinked to unrelated cases, or misapplied to the legal propositions advanced by the respondents.
- Why does X.L. v. Z.L. et al matter for legal AI risk?
- When hyperlinks point to unrelated cases, the court infers AI drafting and awards costs.
- What does the public record establish about X.L. v. Z.L. et al?
- 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.
- Which source supports this X.L. v. Z.L. et al 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.