Lawyer Ordered To Pay Personal Costs For Using Fake AI-generated Case Law (Reddy v Saroya)

In an avoidable yet perhaps inevitable decision, a Canadian court has imposed personal costs against a lawyer for using AI-generated submissions in materials filed with the court: Reddy v Saroya, 2026 ABCA 20 (CanLII).

The decision arose from an appeal decision (2025 ABCA 322), in which the Court of Appeal of Alberta allowed an appeal in part and directed further submissions from the parties to address costs. The submissions on costs were ordered because the appellant's counsel had filed a factum drafted by a contractor using a generative artificial intelligence program which contained references to non-existent authorities.

The underlying circumstances at issue in that case were recently discussed by Stephen Thiele in his article