Denis Sawyer is a lawyer with Murphy's Law, a firm based in Miramichi but serving clients in several locations. (Denis Sawyer/LinkedIn - image credit)
New Brunswick Lawyer Faces First-of-Its-Kind Complaint Over "Fictitious" AI Citations in Court Brief
A New Brunswick lawyer is now facing a disciplinary complaint that the province's law society says is the first of its kind, and the case centers on a problem that's become disturbingly familiar across the legal profession. The Law Society of New Brunswick's disciplinary committee is investigating a complaint against lawyer Denis Sawyer stemming from a brief he submitted to provincial court on April 29, 2025, according to CBC News's reporting on the case.
The complaint alleges Sawyer failed "to use generative artificial intelligence in a competent manner" while preparing the brief, which included 10 "fictitious" citations out of 12 listed in total. When Sawyer was informed of the problem, he filed a revised brief that removed most of the fabricated citations, but still contained two. At the hearing, at opposing counsel's request, Sawyer disavowed both briefs entirely and asked the court to consider only his oral submissions.
A Law Society Facing an Entirely New Kind of Complaint
Joleen Dable, the law society's registrar of complaints, confirmed the organization hasn't previously dealt with a complaint about improper AI use. "The Law Society recognizes that artificial intelligence is becoming an increasingly common tool in the delivery of legal services," Dable said. "The use of AI is not prohibited. However, lawyers remain responsible for complying with their professional obligations, regardless of whether AI is used in the provision of legal services."
Amy Salyzyn, a legal ethics expert, framed the deeper problem the case exposes. "On the one hand, this is a technology issue, they've used AI, but it's also a basic competence issue here as well," she said, according to CBC's reporting. "It means they're not reading the law that they're including to the court, they're, in essence, taking shortcuts. When that happens, that needs to be taken seriously." Sawyer did not respond to CBC's requests for comment and is allowed to continue practicing while the complaint proceeds.
Part of a Growing Pattern Across Canadian Public Institutions
This case adds to a rapidly growing pattern of AI misuse incidents surfacing across Canadian professional and public institutions this year. It follows closely behind New Brunswick MLA Bill Oliver's viral moment reading AI editing instructions aloud during a legislative speech, a story we covered in detail in our piece on Bill Oliver accidentally reading AI prompt text live in the legislature.
That earlier incident has since produced striking data. AI detection company Originality AI analyzed roughly 8,000 English-language speeches delivered in the New Brunswick legislature between 2022 and 2026, finding that just 3.3% of speeches likely contained AI-generated text in 2022, rising to 21% last year and nearly 23% so far in 2026, according to Global News's reporting on the analysis. The scale of that increase suggests AI-assisted content in professional and public settings has become the norm rather than the exception, a trend worth understanding alongside our broader coverage of AI hallucinations and why AI-generated content requires careful human review before it reaches any public-facing context.
Why This Matters for Business
This case is directly relevant for any business relying on legal, compliance, or other professional services where accuracy and accountability carry real consequences. The core issue here isn't AI use itself, since the law society explicitly confirmed AI tools remain permitted, it's the absence of adequate human review before AI-generated work product reached a court of law.
Businesses working with outside counsel, consultants, or any professional services firm should feel comfortable asking directly what AI review processes are in place, particularly for any work product with legal, financial, or regulatory consequences, since this case demonstrates that professional accountability doesn't disappear just because AI assisted with the drafting.
The Fast Version
A New Brunswick lawyer faces the province's first-ever disciplinary complaint over improper AI use, after submitting a court brief containing 10 fabricated legal citations generated by AI. The Law Society of New Brunswick confirmed AI use isn't prohibited, but lawyers remain fully responsible for verifying its output before filing. The case adds to a growing pattern of AI misuse in Canadian public institutions, with AI-generated content now detected in nearly 23% of New Brunswick legislative speeches in 2026.
