Delano Crossing v. County of Wright
Minnesota Tax Court · May 29, 2025
- Jurisdiction
- federal
- Court
- Minnesota Tax Court
- Record ID
- delano-crossing-v-county-of-wright-2025-05-29
- Observed outcome
- The court found a violation of Rule 11.02(b), declined to impose monetary sanctions, and referred the attorney to the Minnesota Lawyers Professional Responsibility Board.
- Known monetary consequence
- $0
Why this matter warrants attention
The Minnesota Tax Court found that counsel violated Rule 11.02(b) by submitting a brief with fake AI-generated citations. The court declined to impose monetary sanctions, determining that the Order to Show Cause and the sanction order were sufficient deterrents, but referred the attorney to the state's professional responsibility board for further investigation.
The court reasoned that Rule 11.02(b) imposes an affirmative duty on counsel to investigate the legal underpinnings of a pleading. It determined that submitting fake citations is inherently misleading and violates this duty. The court found the attorney's 'mistake' defense not credible, concluding that the failure to identify or replace the fake citations before filing demonstrated a lack of reasonable inquiry.
A bar referral can follow even without monetary fines when AI-drafted briefs show a fundamental misunderstanding of the law.
Failure modes and consequences
- Fake Citations
- Misrepresented Authority
- Tax
- Trial
- Monetary
- Professional
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- $0
- Procedural posture
- The matter was heard en banc by the Minnesota Tax Court following an Order to Show Cause regarding the submission of AI-generated fake case citations in a motion for summary judgment.
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 record refers to the tool only as artificial intelligence.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all case citations generated by AI tools before filing.
- Ensure that all legal arguments are supported by existing, verifiable precedent rather than AI-hallucinated authority.
- Establish a review process to confirm that final filings are accurate and do not contain draft-stage errors or AI-generated hallucinations.
- Maintain documentation of the research process to demonstrate compliance with the duty of reasonable inquiry under Rule 11.