Published opinion, 12 February 2026 · source · PDF · 9 pages
He also claims the vexatious litigant designation violates his constitutional rights. The City of Dickinson claims Helgeson’s appellate brief contains fictitious cases and asks us to sanction Helgeson by ordering him to pay the City’s attorney’s fees in this matter. We affirm and sanction Helgeson $500.00.
58 are without merit. V [¶12] The City requests sanctions by way of an award of attorney’s fees against Helgeson for his use of fictitious cases in his appellate brief. The City claims six cases in Helgeson’s brief do not exist.
[¶14] In reviewing the City’s allegations, we determine Helgeson cited several nonexistent cases.
His offered citations lead to different cases that do not support his claims, and a search of the provided case names also is fruitless. The table below lists Helgeson’s fictitious citations and the genuine cases the citations refer to: Helgeson’s Offered Citation Case with Corresponding State Reporter Case with Corresponding Regional Reporter Case with Similar Titles 6 State ex rel. Olson v.
Schneider, 2014 ND 198 855 N.W.2d 399 [¶15] The record also shows Helgeson submitted false citations to the district court. Helgeson does not defend or explain his use of fictitious cases, but instead argues the City’s brief contains incorrect citations. He correctly claims the appellee’s brief miscites State v.
He makes other meritless claims against the City, alleging citation errors. Helgeson wrongly argues we should “disregard Appellee’s claim that Appellant relied on nonexistent authority” because of citation errors in the City’s brief. [¶16] This Court does not appreciate the extra work caused by erroneous citations contained in any party’s brief.
However, the errors in Helgeson’s brief go far beyond a mistake in citation. Five of his cases are fictitious. “Fake or nonexistent legal citations typically are the result of AI ‘hallucinations.’” Mezu v.
Buchholz, 1997 ND 141, ¶ 8, 567 N.W.2d 194 (“[O]ur statutes and rules on procedure will not be modified or applied differently 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 of how the errors came to be, he is responsible for the consequences of his errors, namely the additional workload on the appellee and the courts to address them.