Faulty AI used in legal tribunal

In one of the first cases involving the negligent reliance on AI before Ontario’s disciplinary tribunal for lawyers, a hearing panel ordered full costs against the lawyer that based a motion on faulty AI. The disciplinary action stemmed from an alleged mortgage fraud case.

In 2025, a suspended lawyer, Shahryar Mazaheri, brought a motion before the Law Society Tribunal, seeking to vary the license suspension imposed against him in 2024. And, as part of that proceeding, he brought a second motion seeking to exclude evidence filed by the Law Society, and alleging bias against the panel, seeking their recusal.

However, the tribunal found that his filings on that second motion relied on faulty generative AI.  

“His argument was full of references to non-existent decisions, or decisions that exist but do not stand for the propositions outlined by him,” it said. “The argument was completely incoherent.”

Now, the panel has awarded the Law Society the full costs that it sought on those motions — $31,150, payable immediately. 

It noted that Mazaheri requested that the panel dismiss the costs claim entirely, or award costs of $5,000 or less.

However, the panel sided with the Law Society, saying that this is “a case where it is appropriate to award costs, without any reduction… [as] his irresponsible use of [AI] not only wasted time, cost and effort, it was profoundly improper.”

Among other things, it noted that the respondent’s conduct, including his reliance on faulty AI, needlessly complicated the case.

“As far as we know, this is the first time that a party has included ‘hallucinated; authorities in arguments before the Law Society Tribunal,” it said — adding that this is an emergent issue in other areas of the law. 

“There is a growing understanding in the legal community that unsupervised [AI] tools are unreliable. They will generate fictitious citations, and misunderstand and misrepresent legal concepts,” the tribunal said.

“Yet despite this increased awareness, the number of cases reported … where a court or tribunal has identified that a party has submitted a fictitious citation is going up, not down,” it said — noting that while there were just seven citations in 2024, that rose to 86 in 2025, and 39 in the first quarter of 2026.

While many of these cases involve self-represented litigants, about 18% have been cases involving lawyers.

“If licensees are using [AI] irresponsibly, this raises significant issues,” the tribunal said.

In this case, “Not a single proposition of law in any of the applicant’s materials was supported by a reliable authority. The result was gibberish,” the panel said — as a result, those filings misled the panel, it found.

“The respondent should bear the full cost of his actions. The rest of the professions should not pay for this kind of behaviour,” it said.