Courts on AI / Fabricated or misquoted citations
Nelson v. Derry
Minnesota Court of Appeals · State appellate courts · MN · · 2026 WL 1065922 · No. 62-FA-21-428 ConsideredanddecidedbyLarson,Presiding · opinion
The Minnesota Court of Appeals on 2026-04-15 affirmed the district court’s order and noted that the husband cited an unlocatable DeMars decision resembling an AI hallucination in Nelson v. Derry. The self-represented party filed a brief with one fabricated case citation, including DeMars v. DeMars.
- Disposition
- The court affirmed the district court’s order and noted that the husband cited an unlocatable DeMars decision resembling an AI hallucination.
- Recorded conduct
- The self-represented party filed a brief with one fabricated case citation, including DeMars v. DeMars. — outcome: other; actor: litigant in person
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
, 783 F. Supp. 3d 959, 960 (N. D. Tex. 2025) (“It is no secret that generative [artificial intelligence (AI)] programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs. ” (quoting Sanders v. United States, 176 Fed. Cl. 163, 168-69 (2025))). 4 The Mathews factors require us to consider: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.
Authorities cited in the passage: Sanders v. United States, 176 Fed · Husband cited 'DeMars v. DeMars, 590 N.W.2d 116, 120-21 (Minn. Ct. App. 1999)', which the court was unable to loc
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