Edmonton Articling Student Faces Censure for AI-Generated Legal Appeal
An Edmonton student-at-law has encountered significant professional rebuke after Alberta's legal regulator determined he employed artificial intelligence to draft an appeal challenging an earlier suspension. The case highlights growing concerns about the appropriate use of emerging technologies within the legal profession and the ethical boundaries that must be maintained.
AI Drafting Leads to Hallucinated Legal Citation
Manraj Tiwana was originally suspended for twenty months last year after the Law Society of Alberta discovered he had been accepting clients without informing his articling supervisor. When Tiwana appealed this disciplinary decision, he admitted to using AI to prepare his submissions, which unfortunately included references to a completely fabricated legal case that does not exist in reality.
The seven-member appeal panel expressed particular concern in their March decision, stating: "While we appreciate that Mr. Tiwana was candid in admitting his use of AI, he did not seem to grasp the gravity of misusing it in this way, particularly in this setting, where he is arguing that his discipline was too harsh and his prospect for recovery is good."
The panel further emphasized that "the misuse of AI to write his submissions, and in particular his reliance on a hallucinated case in his submissions, suggests otherwise" regarding his rehabilitation prospects.
Background of Professional Misconduct
The disciplinary issues began in 2022 when the law society received complaints that Tiwana had been accepting off-the-books clients without the knowledge of his supervising lawyer. Investigators found that Tiwana personally accepted payments from these clients while deliberately keeping his principal unaware of these arrangements.
The appeal panel noted that the investigation faced delays "because Mr. Tiwana repeatedly misled the investigators," demonstrating a pattern of deceptive behavior. In 2025, the then-35-year-old lawyer pleaded guilty to six disciplinary charges and agreed to what the hearing panel described as "as lengthy as it gets short of disbarment"—a twenty-month suspension along with $18,000 in costs.
Appeal Process and AI Discovery
Although Tiwana initially accepted the suspension negotiated between the law society and a seasoned defense lawyer, he later appealed the decision, arguing the punishment was excessively severe. During this appeal process, Tiwana represented himself without legal counsel.
According to the appeal decision, a lawyer representing the law society contacted Tiwana before the appeal hearing because she could not locate a case cited in his written submissions. Tiwana responded that it was merely a "placeholder," but further investigation revealed the case had been entirely fabricated by an unspecified artificial intelligence tool.
Panel's Final Decision and Reasoning
The appeal panel ultimately rejected Tiwana's appeal, finding no legal deficiencies in his original guilty plea. The panel reaffirmed that a twenty-month suspension remained appropriate for someone who had demonstrated "abject dishonesty" and engaged in "long-running" attempts to deceive investigators.
The panel also dismissed Tiwana's claim that he didn't fully understand the implications of a twenty-month suspension, including that he would need to apply for readmission or reinstatement afterward with uncertain results, and that his credentials might have expired during that period.
This case serves as a cautionary tale about the responsible integration of artificial intelligence in legal practice, particularly regarding the verification of AI-generated content and maintaining professional standards in disciplinary proceedings.
