It was purpose-built legal AI. It still invented two cases.
Everyone has heard the story by now. Someone used a chatbot, the chatbot made up a case, the court found out. The lesson people take from it is to buy proper legal software instead.
Hussein v Canada (Minister of Immigration, Refugees and Citizenship), 2025 FC 1060, does not support that lesson.
Associate Judge Catharine Moore released it on 28 April 2025. The Court could not locate several of the authorities counsel relied on, and directed him to file a Book of Authorities. The first was incomplete. The second was incomplete too, and contained authorities that had not been there before. Two cases named in the Court's own direction were never produced.
Only after four Directions did counsel explain. He had used a legal research product the Court records as "a professional legal research platform designed specifically for Canadian immigration and refugee law practitioners". He "did not independently verify the citations as they were understood to reflect well established and widely accepted principles of law".
Not a chatbot. Legal software, built for the jurisdiction, built for the practice area. It hallucinated anyway.
And it was worse than two fake cases. The Court found the tool "also hallucinated the proper test for the admission on judicial review of evidence not before the decision-maker and cited, as authority, a case which had no bearing on the issue at all".
That is the part worth sitting with. A case that does not exist announces itself the moment somebody looks for it. A real case, correctly named, cited for a proposition it does not contain, looks like sound research from every angle except the one where you open it.
The Court was not hostile to the technology. Paragraph 39:
The use of generative artificial intelligence is increasingly common and a perfectly valid tool for counsel to use; however, in this Court, its use must be declared and as a matter of both practice, good sense and professionalism, its output must be verified by a human.
What drew the sharpest language was the silence. Counsel's reliance on AI "was not revealed until after the issuance of four Directions". The Court found special reasons warranting costs.
So the question about any legal AI, ours included, is not which product it is. It is two things:
When it gives you a citation, can you open the source and see for yourself? And when it does not know, does it say so?
Juris answers both. Every citation links back to the authority it came from, and anything it cannot confirm is marked unverified rather than presented as law. That is worth more than a feature list, because it is what stands between a busy week and a published judgment with your name in it.
None of this required recklessness. It required one filing nobody opened.
Kwata Team
Source. Hussein v Canada (MIRC), 2025 FC 1060 (Associate Judge Moore, 28 April 2025), Docket IMM-23001-24, paragraphs 34 to 43. The Federal Court's practice direction, The Use of Artificial Intelligence in Court Proceedings, is dated 7 May 2024. Every quotation above was checked word for word against the text of the judgment.
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