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Courts on AI / Fabricated or misquoted citations

In re Marriage of Nelson and Derry

Court of Appeals of Minnesota · State appellate courts · MN · · 2026 WL 1065922 · No. A25-0827 · 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 district court order filing the signed QDRO was affirmed.
Recorded conduct
Nelson’s pro se brief cited DeMars v. DeMars, 590 N.W.2d 116, 120-21 (Minn. Ct. App. 1999), which the court was unable to locate. — outcome: noted, no consequence; 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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