North Dakota · state supreme court · 2026

City of Dickinson v. Helgeson

North Dakota Supreme Court, 12 February 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · N.D.

  1. Court. North Dakota Supreme CourtCOURT
  2. Level. state supreme courtLEVEL
  3. Date. 12 February 2026DATED
  4. Docket. No. No. 20250340DOCKET
  5. Judge. Crothers, Daniel JohnJUDGE
  6. Reporter. 2026 ND 34CITE
  7. Documents. one document, 8 passages quoted belowON FILE
  8. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 12 February 2026 · source · PDF · 9 pages

He also claims the vexatious litigant designation violates his constitutional rights. The City of Dickinson claims Helgeson’s appellate brief contains fictitious cases and asks us to sanction Helgeson by ordering him to pay the City’s attorney’s fees in this matter. We affirm and sanction Helgeson $500.00.

58 are without merit. V [¶12] The City requests sanctions by way of an award of attorney’s fees against Helgeson for his use of fictitious cases in his appellate brief. The City claims six cases in Helgeson’s brief do not exist.

[¶14] In reviewing the City’s allegations, we determine Helgeson cited several nonexistent cases.

His offered citations lead to different cases that do not support his claims, and a search of the provided case names also is fruitless. The table below lists Helgeson’s fictitious citations and the genuine cases the citations refer to: Helgeson’s Offered Citation Case with Corresponding State Reporter Case with Corresponding Regional Reporter Case with Similar Titles 6 State ex rel. Olson v.

Schneider, 2014 ND 198 855 N.W.2d 399 [¶15] The record also shows Helgeson submitted false citations to the district court. Helgeson does not defend or explain his use of fictitious cases, but instead argues the City’s brief contains incorrect citations. He correctly claims the appellee’s brief miscites State v.

He makes other meritless claims against the City, alleging citation errors. Helgeson wrongly argues we should “disregard Appellee’s claim that Appellant relied on nonexistent authority” because of citation errors in the City’s brief. [¶16] This Court does not appreciate the extra work caused by erroneous citations contained in any party’s brief.

However, the errors in Helgeson’s brief go far beyond a mistake in citation. Five of his cases are fictitious. “Fake or nonexistent legal citations typically are the result of AI ‘hallucinations.’” Mezu v.

Buchholz, 1997 ND 141, ¶ 8, 567 N.W.2d 194 (“[O]ur statutes and rules on procedure will not be modified or applied differently merely because a party not learned in the law is acting pro se.”). For our purposes here, it does not matter whether Helgeson’s fictitious cases and erroneous citations were AI-generated or the result of careless work. Rather, regardless of how the errors came to be, he is responsible for the consequences of his errors, namely the additional workload on the appellee and the courts to address them.

What the text mentions

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Where this fits

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More from North Dakota Supreme Court, from North Dakota, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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