Ko v. Li
In an estates matter, counsel's factum cited multiple non-existent cases — one hyperlink returned a 404 error, another redirected to an unrelated decision. The court ordered counsel to show cause for contempt. Subsequent hearings found that counsel's admission and corrective steps purged the contempt.
| Court | Ontario Superior Court of Justice |
|---|---|
| Citation | 2025 ONSC 2766 |
| Case number | CV-25-00736891-00ES |
| Jurisdiction | Ontario |
| Decided | |
| Parties | Plaintiff / Applicant: Hanna Ko Defendant / Respondent: Estate of Xiang Guo Li |
| Judge | Justice Alex Finlayson |
AI context
AI system: Generative AI tool (specific product not confirmed)
Counsel appears to have used a large language model to draft the factum. Fabricated citations were incorporated and filed without verification. The specific AI tool was not confirmed in the public record.
Significance
First Ontario case invoking contempt of court proceedings for AI-hallucinated citations. Established that fabricated citations can constitute contempt, though sincere admission and corrective steps can purge it.
Outcome
SanctionsCounsel ordered to show cause for contempt of court. Subsequent hearings (2025 ONSC 2965, 2025 ONSC 6785) found that counsel's admission, apology, and corrective steps purged the contempt.