Nelson v. Derry
Minnesota · Apr 15, 2026
- Jurisdiction
- state
- Court
- Minnesota
- Record ID
- nelson-v-derry-2026-04-15
- Observed outcome
- The district court's order was affirmed; the appellate court rejected all four of the appellant's arguments.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Minnesota Court of Appeals identified that a pro se litigant submitted a fake, hallucinated case citation ('DeMars v. DeMars') in his appellate brief. The court explicitly flagged this as an example of AI-generated hallucinations, noting that such nonexistent cases are increasingly appearing in filings, and relied on federal precedent to characterize the nature of the error.
The court reasoned that the citation was nonexistent and linked the error to the known phenomenon of AI-generated hallucinations, referencing federal case law (Willis v. U.S. Bank Nat'l Ass'n) to contextualize the prevalence of fake citations in modern litigation.
This case illustrates the judicial response to AI-hallucinated citations in pro se filings. It demonstrates that courts are increasingly identifying and documenting the use of AI-generated fake authorities, providing a clear record of how such errors are addressed within appellate opinions.
Failure modes and consequences
- Pro Se
- Fake Citations
- Family
- Trial
- None Adjudicated
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a district court order compelling the execution of a Qualified Domestic Relations Order (QDRO).
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 identified the citation as a hallucination linked to AI programs.
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
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.