Jisuh Lee referred for criminal contempt over AI-generated fake citations in Ontario court
Ontario lawyer Jisuh Lee submitted a factum with hallucinated or misattributed citations generated by ChatGPT. After initially denying AI involvement, she admitted using AI, and a court referral to the Attorney General followed for potential contempt.
Records by entity: Jisuh Lee
Ontario lawyer Jisuh Lee was referred for criminal contempt after using ChatGPT to generate fake case law and lying to the court.
You can delegate drafting to an algorithm, but you cannot delegate your integrity.
Key facts
- What
- Ontario lawyer Jisuh Lee submitted a factum with hallucinated or misattributed citations generated by ChatGPT.
- Incident date
- May 1, 2025
- Who
- Jisuh Lee
- Failure mode
- Hallucination
- AI surface
- Chatbot
- Severity
- Catastrophic
What happened
In Ko v. Li, 2025 ONSC 6785, attorney Jisuh Lee used ChatGPT to draft a legal factum that included four non-existent case citations. When confronted by Justice Fred Myers, Lee denied AI involvement and claimed a student did the work. She later admitted to the court that there was no student and that she had used ChatGPT to draft the factum.
What broke inside the model
- 01 · TriggerA user asks for a fact, a citation, or a figure.
- 02 · Model stepThe model writes a fluent, confident answer.
- 03 · Control gapNothing ties the claim back to a real source.
- 04 · FailureA fabricated fact ships as if it were verified.
- 05 · ConsequenceThe false claim reaches a customer, a court, or the public.
Confidence holds, and even spikes, as the claim detaches from any source.
The LLM hallucinated legal precedents, creating citations that appeared authentic but were non-existent. The failure was compounded by the lawyer's failure to verify the AI output and subsequent attempts to deceive the court.
What it cost
Sources
Cite this entry
https://failureindex.ai/failures/jisuh-lee-referred-criminal-contempt-generatedAI Failure Index. "Jisuh Lee referred for criminal contempt over AI-generated fake citations in Ontario court" (FI-0270). Realm Labs. https://failureindex.ai/failures/jisuh-lee-referred-criminal-contempt-generated (indexed Jun 5, 2026).Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0270. Full dataset at /data.
Note from Realm Labs, the Index steward
How Realm would have caught this
- Prism
- OmniGuard
- AI Detection & Response (AIDR)
A runtime layer that watches the model's internal state can flag the moment a model commits to a claim it has no support for, and hold or reroute the response before it reaches a user. Realm reads those signals in real time rather than grading the transcript after the fact.