City of Dickinson v. Helgeson
SC North Dakota · Feb 12, 2026
- Jurisdiction
- state
- Court
- SC North Dakota
- Record ID
- city-of-dickinson-v-helgeson-2026-02-12-2
- Observed outcome
- The court affirmed the vexatious litigant designation and imposed a $500 monetary sanction against the appellant.
- Known monetary consequence
- $500
Why this matter warrants attention
The Supreme Court of North Dakota sanctioned a pro se litigant $500 for including multiple fictitious legal citations in his appellate brief. The court held that regardless of whether the errors were AI-generated or the result of carelessness, the litigant is responsible for the consequences of his filings and the resulting burden on the judicial process.
Fabricated: Case Law | Court found the cited State v. Rogers, 2006 ND 85 712 N.W.2d 841 listed by Helgeson did not match the authority he relied on and was among the fictitious citations. || Fabricated: Case Law | Appellant cited 'State v. Clark, 2012 ND 135, 818 N.W.2d 739' among other offered authorities; the court determined several of these offered citations were fictitious or misleading. || Fabricated: Case Law | Court found 'State ex rel. Olson v. City of Fargo, 250 N.W.2d 558 (N.D. 1977)' does not exist; court matched it to unrelated real reporters/titles and deemed it fictitious. || Fabricated: Case Law | Court determined the cited State v. $44,140.00 U.S. Currency, 2003 ND 28 657 N.W.2d 829 is a nonexistent authority in Helgeson's brief. || Fabricated: Case Law | Court identified the citation State v. Clark, 2022 ND 85 999 N.W.2d 632 in Helgeson's brief as not corresponding to the asserted authority and found it fictitious as presented. || Fabricated: Case Law | Court concluded the citation State ex rel. Stenehjem v. FreeEats.com Inc., 712 N.W.2d 828, 841 (N.D. 2006) as used by Helgeson was not an accurate existing authority and was treated as fictitious. || Fabricated: Case Law | Appellant cited 'State ex rel. Olson v. City of Fargo, 250 N/A' in his brief; the court found the citation to be nonexistent after searching and listed a different, genuine Olson decision as unrelated. || Fabricated: Case Law | Appellant cited 'State v. $44,140.00 U.S. Currency, 2003 ND 28, 657 N.W.2d 829' which the court determined did not exist as offered and did not support his arguments. || Fabricated: Case Law | Appellant cited 'State v. $44,140.00 U.S. Currency, 2012 ND 176, 820 N.W.2d 697' as authority; the court found the offered citation to be fictitious and not the authority relied upon. || Fabricated: Case Law | Appellant cited 'State v. Clark, 2022 ND 85, 999 N.W.2d 632' in his brief but the court found the citation did not correspond to supporting authority as offered. || Fabricated: Case Law | Court found 'State v. $44,140.00 U.S. Currency, 2003 ND 28 657 N.W.2d 829' as offered by Helgeson was nonexistent or misreferenced and did not support his claims. || Fabricated: Case Law | Court identified 'State v. $44,140.00 U.S. Currency, 2012 ND 176, 820 N.W.2d 697' in Helgeson's brief as a non-existent or incorrect citation and treated it as fictitious. || Fabricated: Case Law | Court noted 'State v. Clark, 2022 ND 85, 999 N.W.2d 632' as offered by Helgeson did not correspond to the cited authorities and was treated as a nonexistent/misleading citation. || Fabricated: Case Law | Court found 'State ex rel. Stenehjem v. FreeEats.com Inc., 712 N.W.2d 828, 841 (N.D. 2006)' in Helgeson's brief to be a fictitious citation that did not exist as cited. || Fabricated: Case Law | Court found the cited State ex rel. Olson v. City of Fargo, 250 N.W.2d 558 (N.D. 1977) does not exist and the offered citation does not support Helgeson's claim.
This record documents a Pro Se Litigant filing issue in SC North Dakota, with the listed outcome: Monetary Sanction.
Failure modes and consequences
- Pro Se
- Fake Citations
- Other
- Trial
- Monetary
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- $500
- Procedural posture
- Appeal from a district court order designating the appellant as a vexatious litigant.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court noted that fake citations are typically the result of AI hallucinations.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.