City of Dickinson v. Helgeson

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

N.W.2d 811 2016 ND 198 N.W.2d 807, 811 N.W.2d 399 (Wis. Ct. App. 2016) [¶17] Like our sister states, we view the use of AI- [¶15] The record also shows Helgeson submitted false related technology as a means of improving access to citations to the district court. Helgeson does not defend or explain his use of fictitious cases, but instead argues the courts. See, e.g., Illinois Supreme Court, Policy on the City's brief contains incorrect citations. He correctly Artificial Intelligence (2024) (noting the use of AI can improve access to justice and “should not be discouraged” claims the appellee's brief miscites State v. Kovalevich, 2023 if it is reviewed and falls within ethical guidelines); Chief ND 206, 997 N.W.2d 628, as a 2003 case, and People v. Justice G. Richard Bevan, AI in the Courts: Balancing Marshall, 73 Mich.App. 97, 250 N.W.2d 557 (1976) as Tradition and Innovation, Idaho State Bar (Dec. 29, a 1994 case. He makes other meritless claims against the 2025), https://isb.idaho.gov/blog/ai-in-the-courts-balancing- City, alleging citation errors. Helgeson wrongly argues we tradition-and-innovation-by-chief-justice-g-richard-bevan should “disregard Appellee's claim that Appellant relied on (“We cannot ignore technology that may serve people better nonexistent authority” because of citation errors in the City's brief. or help us work more efficiently.”); Willis v. U.S. Bank Nat'l Ass'n as Tr., Igloo Series Trust, 783 F. Supp. 3d 959, 960 (N.D. [¶16] This Court does not appreciate the extra work caused by Tex. 2025) (“AI is a powerful tool, that when used prudently, erroneous citations contained in any party's brief. However, provides immense benefits.’ AI also ‘may ultimately prove a the errors in Helgeson's brief go far beyond a mistake in helpful tool to assist pro se litigants in bringing meritorious citation. Five of his cases are fictitious. “Fake or nonexistent cases to the courts,’ ....”). legal citations typically are the result of AI ‘hallucinations.’ ” Mezu v. Mezu, 267 Md.App. 354, 346 A.3d 181, 189 (2025) *5 [¶18] That said, the use of technology, especially (citing Noland v. Land of the Free, L.P., 114 Cal.App.5th developing technology like AI, requires careful use and 426, 336 Cal. Rptr. 3d 897, 911 (2025)). By this statement scrupulous verification of the arguments and authorities and citation, we do not criticize the use of AI or AI-assisted generated by anyone using the tool. Evenstad v. Buchholz, tools. To the contrary, we encourage and embrace the use 1997 ND 141, ¶ 8, 567 N.W.2d 194 (“[O]ur statutes and of technology to improve the work product of all litigants, rules on procedure will not be modified or applied differently whether represented or self-represented. merely because a party not learned in the law is acting pro se.”). For our purposes here, it does not matter whether Helgeson's fictitious cases and erroneous citations were AI- generated or the result of careless work. Rather, regardless City of Dickinson v. Helgeson, --- N.W.3d ---- (2026) 2026 ND 34 noncriminal, and the district court did not abuse its discretion

Authorities cited in the passage: State v. Clark, 2012 ND 135, 818 N.W.2d 739 · State ex rel. Olson v. City of Fargo, 250 N.W.2d 558 (N.D. 1977) · s brief. || Fabricated: Case Law | Court identified the citation State v. Clark, 2022 ND 85 999 N.W.2d 632 in Helgeson · State ex rel. Olson v. City of Fargo, 250 N/A · State v. $44,140.00 U.S. Currency, 2003 ND 28, 657 N.W.2d 829 · State v. $44,140.00 U.S. Currency, 2012 ND 176, 820 N.W.2d 697 · State v. Clark, 2022 ND 85, 999 N.W.2d 632 · State v. $44,140.00 U.S. Currency, 2003 ND 28 657 N.W.2d 829 · s brief as a non-existent or incorrect citation and treated it as fictitious. || Fabricated: Case Law | Court noted · as offered by Helgeson did not correspond to the cited authorities and was treated as a nonexistent/misleading citation. || Fabricated: Case Law | Court found · in Helgeson · State v. Kovalevich, 2023 if it is reviewed and falls within ethical guidelines)