What was hallucinated

Fabricated: Case Law | County's summary judgment brief contained five AI-generated case citations that do not correspond to any actual judicial decisions; the court found them fake and inherently misleading under Rule 11. || Misrepresented: Case Law | At the hearing, County offered substitute real cases to support its propositions, but the court found those authorities did not support the brief’s arguments. || Misrepresented: Legal Norm | Brief asserted that failure to comply with deadlines or court orders can justify granting summary judgment; the court held this sweeping proposition is unsupported and misplaced. || Misrepresented: Legal Norm | AI-generated brief relied on Minn. R. Civ. P. 41 (dismissal) while moving under Rule 56 for summary judgment; the court found no authority granting summary judgment for such procedural deficiencies.

Details

AI UseAttorneys for Wright County submitted a memorandum in support of a motion for summary judgment that contained five case citations generated by artificial intelligence; these citations did not refer to actual judicial decisions. Much of the brief appeared to be AI-written. The attorney who signed and filed the brief, acknowledged that the cited authorities did not exist and that much of the brief was drafted by AI.Ruling/SanctionThe Court found Counsel's conduct violated Rule 11.02(b) of the Minnesota Rules of Civil Procedure, as fake case citations cannot support any legal claim and there's an affirmative duty to investigate the legal underpinnings of a pleading. The Court found no merit in Counsel's defense, noting that the substitute cases she offered did not support the legal contentions in the brief, and the brief demonstrated a fundamental misunderstanding of legal standards. The Court did not find her insinuation that another, accurate motion document existed to be credible.Although the Court considered summarily denying the County's motion as a sanction, it ultimately denied the motion on its merits in a concurrent order because the arguments were so clearly incorrect.The Court declined to order further monetary sanctions, believing its Order to Show Cause and the current Order on Sanctions were sufficient to deter Counsel from relying solely on AI for case citations or legal conclusions in the future. However, the Court referred the matter concerning Counsel's conduct to the Minnesota Lawyers Professional Responsibility Board for further review, as the submission of an AI-generated brief with fake citations raised questions regarding her honesty, trustworthiness, and fitness as a lawyer.

Sanction teardown · Minnesotta Tax Court, USA · 2025-05-29

Delano Crossing v. County of Wright

What happened

In Minnesotta Tax Court, 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)

County's summary judgment brief contained five AI-generated case citations that do not correspond to any actual judicial decisions; the court found them fake and inherently misleading under Rule 11.
Misrepresented (Case Law)

At the hearing, County offered substitute real cases to support its propositions, but the court found those authorities did not support the brief’s arguments.
Misrepresented (Legal Norm)

Brief asserted that failure to comply with deadlines or court orders can justify granting summary judgment; the court held this sweeping proposition is unsupported and misplaced.
Misrepresented (Legal Norm)

AI-generated brief relied on Minn. R. Civ. P. 41 (dismissal) while moving under Rule 56 for summary judgment; the court found no authority granting summary judgment for such procedural deficiencies.

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

Breach of Rule 11, but no monetary sanction warranted; referred counsel to Lawyers Professional Responsibility Board

Additional detail

AI UseAttorneys for Wright County submitted a memorandum in support of a motion for summary judgment that contained five case citations generated by artificial intelligence; these citations did not refer to actual judicial decisions. Much of the brief appeared to be AI-written. The attorney who signed and filed the brief, acknowledged that the cited authorities did not exist and that much of the brief was drafted by AI.Ruling/SanctionThe Court found Counsel's conduct violated Rule 11.02(b) of the Minnesota Rules of Civil Procedure, as fake case citations cannot support any legal claim and there's an affirmative duty to investigate the legal underpinnings of a pleading. The Court found no merit in Counsel's defense, noting that the substitute cases she offered did not support the legal contentions in the brief, and the brief demonstrated a fundamental misunderstanding of legal standards. The Court did not find her insinuation that another, accurate motion document existed to be credible.Although the Court considered summarily denying the County's motion as a sanction, it ultimately denied the motion on its merits in a concurrent order because the arguments were so clearly incorrect.The Court declined to order further monetary sanctions, believing its Order to Show Cause and the current Order on Sanctions were sufficient to deter Counsel from relying solely on AI for case citations or legal conclusions in the future. However, the Court referred the matter concerning Counsel's conduct to the Minnesota Lawyers Professional Responsibility Board for further review, as the submission of an AI-generated brief with fake citations raised questions regarding her honesty, trustworthiness, and fitness as a lawyer.

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/459/Delano_Crossing_2016_v._County_of_Wright_Minnesota_Tax_Court_29_May_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).