What was hallucinated

Fabricated: Case Law | Court found the cited State v. Rogers, 2006 ND 85 712 N.W.2d 841 listed by Helgeson did not match the authority he relied on and was among the fictitious citations. || Fabricated: Case Law | Appellant cited 'State v. Clark, 2012 ND 135, 818 N.W.2d 739' among other offered authorities; the court determined several of these offered citations were fictitious or misleading. || Fabricated: Case Law | Court found 'State ex rel. Olson v. City of Fargo, 250 N.W.2d 558 (N.D. 1977)' does not exist; court matched it to unrelated real reporters/titles and deemed it fictitious. || Fabricated: Case Law | Court determined the cited State v. $44,140.00 U.S. Currency, 2003 ND 28 657 N.W.2d 829 is a nonexistent authority in Helgeson's brief. || Fabricated: Case Law | Court identified the citation State v. Clark, 2022 ND 85 999 N.W.2d 632 in Helgeson's brief as not corresponding to the asserted authority and found it fictitious as presented. || Fabricated: Case Law | Court concluded the citation State ex rel. Stenehjem v. FreeEats.com Inc., 712 N.W.2d 828, 841 (N.D. 2006) as used by Helgeson was not an accurate existing authority and was treated as fictitious. || Fabricated: Case Law | Appellant cited 'State ex rel. Olson v. City of Fargo, 250 N/A' in his brief; the court found the citation to be nonexistent after searching and listed a different, genuine Olson decision as unrelated. || Fabricated: Case Law | Appellant cited 'State v. $44,140.00 U.S. Currency, 2003 ND 28, 657 N.W.2d 829' which the court determined did not exist as offered and did not support his arguments. || Fabricated: Case Law | Appellant cited 'State v. $44,140.00 U.S. Currency, 2012 ND 176, 820 N.W.2d 697' as authority; the court found the offered citation to be fictitious and not the authority relied upon. || Fabricated: Case Law | Appellant cited 'State v. Clark, 2022 ND 85, 999 N.W.2d 632' in his brief but the court found the citation did not correspond to supporting authority as offered. || Fabricated: Case Law | Court found 'State v. $44,140.00 U.S. Currency, 2003 ND 28 657 N.W.2d 829' as offered by Helgeson was nonexistent or misreferenced and did not support his claims. || Fabricated: Case Law | Court identified 'State v. $44,140.00 U.S. Currency, 2012 ND 176, 820 N.W.2d 697' in Helgeson's brief as a non-existent or incorrect citation and treated it as fictitious. || Fabricated: Case Law | Court noted 'State v. Clark, 2022 ND 85, 999 N.W.2d 632' as offered by Helgeson did not correspond to the cited authorities and was treated as a nonexistent/misleading citation. || Fabricated: Case Law | Court found 'State ex rel. Stenehjem v. FreeEats.com Inc., 712 N.W.2d 828, 841 (N.D. 2006)' in Helgeson's brief to be a fictitious citation that did not exist as cited. || Fabricated: Case Law | Court found the cited State ex rel. Olson v. City of Fargo, 250 N.W.2d 558 (N.D. 1977) does not exist and the offered citation does not support Helgeson's claim.

Sanction teardown · SC North Dakota, USA · 2026-02-12

City of Dickinson v. Helgeson

What happened

In SC North Dakota, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Court found the cited State v. Rogers, 2006 ND 85 712 N.W.2d 841 listed by Helgeson did not match the authority he relied on and was among the fictitious citations.
Fabricated (Case Law)

Appellant cited 'State v. Clark, 2012 ND 135, 818 N.W.2d 739' among other offered authorities; the court determined several of these offered citations were fictitious or misleading.
Fabricated (Case Law)

Court found 'State ex rel. Olson v. City of Fargo, 250 N.W.2d 558 (N.D. 1977)' does not exist; court matched it to unrelated real reporters/titles and deemed it fictitious.
Fabricated (Case Law)

Court determined the cited State v. $44,140.00 U.S. Currency, 2003 ND 28 657 N.W.2d 829 is a nonexistent authority in Helgeson's brief.
Fabricated (Case Law)

Court identified the citation State v. Clark, 2022 ND 85 999 N.W.2d 632 in Helgeson's brief as not corresponding to the asserted authority and found it fictitious as presented.
Fabricated (Case Law)

Court concluded the citation State ex rel. Stenehjem v. FreeEats.com Inc., 712 N.W.2d 828, 841 (N.D. 2006) as used by Helgeson was not an accurate existing authority and was treated as fictitious.
Fabricated (Case Law)

Appellant cited 'State ex rel. Olson v. City of Fargo, 250 N/A' in his brief; the court found the citation to be nonexistent after searching and listed a different, genuine Olson decision as unrelated.
Fabricated (Case Law)

Appellant cited 'State v. $44,140.00 U.S. Currency, 2003 ND 28, 657 N.W.2d 829' which the court determined did not exist as offered and did not support his arguments.
Fabricated (Case Law)

Appellant cited 'State v. $44,140.00 U.S. Currency, 2012 ND 176, 820 N.W.2d 697' as authority; the court found the offered citation to be fictitious and not the authority relied upon.
Fabricated (Case Law)

Appellant cited 'State v. Clark, 2022 ND 85, 999 N.W.2d 632' in his brief but the court found the citation did not correspond to supporting authority as offered.
Fabricated (Case Law)

Court found 'State v. $44,140.00 U.S. Currency, 2003 ND 28 657 N.W.2d 829' as offered by Helgeson was nonexistent or misreferenced and did not support his claims.
Fabricated (Case Law)

Court identified 'State v. $44,140.00 U.S. Currency, 2012 ND 176, 820 N.W.2d 697' in Helgeson's brief as a non-existent or incorrect citation and treated it as fictitious.
Fabricated (Case Law)

Court noted 'State v. Clark, 2022 ND 85, 999 N.W.2d 632' as offered by Helgeson did not correspond to the cited authorities and was treated as a nonexistent/misleading citation.
Fabricated (Case Law)

Court found 'State ex rel. Stenehjem v. FreeEats.com Inc., 712 N.W.2d 828, 841 (N.D. 2006)' in Helgeson's brief to be a fictitious citation that did not exist as cited.
Fabricated (Case Law)

Court found the cited State ex rel. Olson v. City of Fargo, 250 N.W.2d 558 (N.D. 1977) does not exist and the offered citation does not support Helgeson's claim.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Monetary Sanction (monetary penalty: 500 USD.)

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

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Source: https://www.damiencharlotin.com/documents/1488/City_of_Dickinson_v_Helgeson.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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