A New Brunswick lawyer is facing the first known complaint in the province over improper use of artificial intelligence in legal work. Denis Sawyer is accused of submitting a brief to provincial court with 10 fictitious citations out of 12 listed, according to a public notice from the Law Society of New Brunswick.
The alleged misconduct stems from a brief Sawyer filed on April 29, 2025. The law society says he failed "to use generative artificial intelligence in a competent manner" while preparing the document. When opposing counsel flagged the fabricated citations, Sawyer filed a revised brief that removed most of them but left two intact, the notice states. At a subsequent hearing, he disavowed both briefs and asked the court to consider only his oral submissions.
Sawyer, a lawyer with Miramichi-based Murphy's Law, has taken "full responsibility" for the details of the complaint, calling the incident an "oversight." The law society's discipline committee will hold hearings on September 3. He is allowed to continue practising in the meantime.
The allegations
The complaint does not identify the case or the subject of Sawyer's brief. According to the law society, 10 of the 12 citations in the original document were "fictitious."
Joleen Dable, the registrar of complaints, said the society had not previously dealt with a complaint about improper AI use. "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," Dable said in an email.
Law society's response
The society has formed a task force to develop guidance on the appropriate and responsible use of AI, Dable said, citing the "evolving role of AI in legal practice." She declined to comment further on the active disciplinary case.
Lawyers who use AI must still meet professional standards, including protecting client confidentiality and verifying the accuracy of information, she added.
Expert warns of 'machine fabrications'
Amy Salyzyn, a legal ethics professor at the University of Ottawa, said Canada has seen an "accelerating trend" of AI-related complaints against lawyers since 2023. "We need to make sure that we try to stem this accelerating tide, because it doesn't show any signs of going away on its own," she said.
Salyzyn warned that submitting fictitious case law created by AI undermines the integrity of the justice system. "When you have a machine interjecting things that are simply fictional creations, you don't really have rule by law. You have rule by machine fabrications," she said. "And that's really fundamentally contrary to our understanding of what it means to administer justice in a fair way."
She described the issue as a basic competence problem: lawyers are not reading the law they submit to the court and are taking shortcuts. "When that happens, that needs to be taken seriously."
Why this matters for legal professionals
This case signals that regulators will treat AI misuse as a professional conduct matter, not a technology glitch. Legal professionals must verify any AI-generated citations or content before submitting it to a court or client. Competence now includes understanding how generative AI works and where it fails. Law societies across Canada are developing guidance and training resources, but ultimately the lawyer is responsible for every document that bears their name. Familiarity with ethical AI practices - such as those covered in professional responsibility resources - is no longer optional. The cost of an "oversight" can range from a disciplinary hearing to lasting damage to a lawyer's reputation and career.
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