Courts on AI / Fabricated or misquoted citations
Mohamed Ali v. Saeed Osman
Supreme Court of North Dakota · State supreme courts · ND · · 2026 ND 156 · No. 20260029 · opinion
The North Dakota Supreme Court affirms and remands in a divorce dispute and separately sanctions self-represented appellant Mojahid Osman. The court says Osman corrected two nonexistent citations but ignored many unrelated authorities, and awards Sara Ali $1,000 for multiple fictitious or nonexistent citation errors.
- Disposition
- The court affirmed and remanded, awarding Ali $1,000 in sanctions for citation errors in Osman's opening brief.
- Recorded conduct
- Self-represented appellant filed an opening brief with multiple fictitious or nonexistent citations and citations unrelated to the stated propositions. — outcome: sanctions; actor: litigant in person; $1,000
- 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.
We conclude Osman’s appeal is not completely frivolous; therefore, we do not sanction under N.D.R.App.P 38 as requested. Nevertheless, while Osman corrected two nonexistent citations, he failed to acknowledge numerous other citations wholly unrelated to the propositions for which they were cited. Under N.D.R.App.P. 28(b)(2) and (7), a party’s brief must provide citations to authorities, and under Rule 28(l), the brief must be accurate and free from irrelevant matters. Under N.D.R.App.P. 13, this court “may take appropriate action against any person failing to perform an act required by rule or court order.” We conclude a sanction is appropriate based on the multiple fictitious or nonexistent citation errors in his opening brief. See City of Dickinson v. Helgeson, 2026 ND 34, ¶¶ 16, 19, 31 N.W.3d 672 (awarding $500 as a sanction for misconduct based on fake or nonexistent legal citations); Stokka v. Stokka, 2026 ND 94, ¶¶ 4-5, 35 N.W.3d 207 (citing Helgeson and imposing costs and attorney’s fees of $1,000, noting the “few legal authorities cited” were “either irrelevant, fictitious, or nonexistent”). We therefore award Ali sanctions in the amount of $1,000.
Authorities cited in the passage: N.D.R.App.P. 13 · N.D.R.App.P. 28 · N.D.R.App.P. 38 · City of Dickinson v. Helgeson, 2026 ND 34 · Stokka v. Stokka, 2026 ND 94
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