Reddy v Saroya, 2026 ABCA 20 — Appeal No. 2401-0228AC (Released January 22, 2026)

Unknown / Not Disclosed no_human_verification; fabricated_case_citations; third_party_vendor_or_contractor_use; failure_to_supervise

I. Executive Summary

The Alberta Court of Appeal ordered personal costs against a lawyer after appellate filings included citations to non-existent precedents described as having been generated by an AI tool. The court treated the “unchecked use of AI” as resulting in a misleading factum and a waste of time and resources for the opposing party and the court. The court held the circumstances amounted to sufficiently serious misconduct to justify a costs award payable personally by lead counsel.

II. Conduct Analysis

Counsel filed appellate materials that cited non-existent authorities reportedly produced via an external contractor’s use of generative AI, without adequate verification before filing.

III. Legal Foundations

Alberta Rules of Court (personal costs rule referenced in reporting); court’s inherent/express costs powers (as applied to misleading filings and serious misconduct)

IV. Key Facts

The court addressed non-existent precedents in appellate filings attributed to AI use and ordered costs against the lawyer personally; the reported quantum was $17,550 plus GST.

V. Consequences & Sanction

Personal costs ordered against lead counsel (CAD 17,550 plus GST).