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Courts on AI / Fabricated or misquoted citations

Rushing v. Rushing et al. and Christ Temple Apostolic Church-Fridley

Minnesota Court of Appeals · State appellate courts · MN · · 2026 WL 905119 · No. APP. with Minn. R. Civ. P. 11.02(b) · order

On 2026-03-31, Minnesota Court of Appeals allowed the dismissal of the appellant’s action without prejudice to stand after rejecting his challenge to the AI-citation sanction. A self-represented party submitted a complaint with fabricated or nonexistent authorities. The court resolved the merits while identifying the defective legal research.

Disposition
The court allowed the dismissal of the appellant’s action without prejudice to stand after rejecting his challenge to the AI-citation sanction.
Recorded conduct
The complaint used fabricated or nonexistent authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted. — outcome: dismissal; 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.

SPECIAL TERM ORDER1 409 (Minn. App. 1989), rev. denied (Minn. July 12, 1989). Jennifer L. Frisch Chief Judge Appellant contends that the March 5, 2026 order dismissing *1 BASED ON THE FILE, RECORD, AND appellant's action without prejudice affected appellant's PROCEEDINGS, AND FOR THE FOLLOWING substantial rights. Appellant notes that the dismissal was REASONS: “based on [an] alleged citation to nonexistent legal authority” and asserts that the district court “rendered the alleged defect This appeal was filed on March 10, 2026. According to the uncurable” by refusing to accept an amended complaint fixing notice of appeal, appellant Marcus Rushing seeks review the citation issue it identified. of a March 9, 2026 order denying appellant's motion to vacate a March 5, 2026 dismissal order. In a March 11, In the March 5, 2026 dismissal order, the district court did 2026 order, we questioned (a) whether the March 5, 2026 not decide the merits of any of appellant's claims. Because order dismissing appellant's action without prejudice affected the district court's dismissal of appellant's action without appellant's substantial rights; (b) if not, whether the March 9, prejudice does not prevent appellant from serving

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