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Corpus matter record

Volker v. Nygaard

SC North Dakota · Feb 26, 2026

ND / stateEditorial impact: career endingpro sefake citationsothertrialCase Dismissed
Direct answer

What happened in this matter?

The district court dismissed the plaintiff's claims with prejudice as a Rule 11 sanction after finding the litigant repeatedly submitted fictitious, AI-generated case citations. The North Dakota Supreme Court subsequently dismissed the plaintiff's appeal as untimely, thereby upholding the district court's judgment and sanction.

Why the court cared
Fabricated: Case Law | Volker repeatedly filed briefs containing fictitious, AI-generated case citations; the district court found them fictitious and dismissed the case with prejudice as a Rule 11 sanction.
Why it matters now
This record documents a Pro Se Litigant filing issue in SC North Dakota, with the listed outcome: Case dismissed with prejudice.

Why this matter is tracked

In Volker v. Nygaard, the North Dakota Supreme Court dismissed an appeal by a pro se litigant as untimely. The underlying district court action involved the plaintiff, Scott Volker, who repeatedly submitted briefs containing fictitious, AI-generated case citations. Despite warnings from the district court, Volker continued to file such briefs. Consequently, the district court issued an Order to Show Cause and subsequently dismissed the action with prejudice as a Rule 11, N.D.R.Civ.P., sanction for willful defiance. The Supreme Court determined that the appeal was filed after the 90-day jurisdictional deadline, as the ministerial insertion of statutory costs into the judgment did not restart the appeal period, leaving the district court's dismissal sanction in place.

Operational lesson

This record documents a Pro Se Litigant filing issue in SC North Dakota, with the listed outcome: Case dismissed with prejudice.

Record details

North DakotaSingle-state evidence scope
Explore NDOpen its source-linked jurisdiction page and related matters.
CourtSC North Dakota
Jurisdictionstate
Circuit8th Circuit
DateFeb 26, 2026
AI
AI toolAI (unspecified)
Party typePro Se Litigant
OutcomeThe district court dismissed the case with prejudice as a Rule 11 sanction; the Supreme Court dismissed the appeal as untimely.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

explicitly recorded

The court explicitly refers to the citations as AI-generated.

Procedural posture

The district court dismissed the action with prejudice as a Rule 11 sanction. The North Dakota Supreme Court dismissed the subsequent appeal as untimely.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

1 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Volker repeatedly filed briefs containing fictitious, AI-generated case citations; the district court found them fictitious and dismissed the case with prejudice as a Rule 11 sanction.

Questions this record answers

What happened in Volker v. Nygaard?
The district court dismissed the plaintiff's claims with prejudice as a Rule 11 sanction after finding the litigant repeatedly submitted fictitious, AI-generated case citations. The North Dakota Supreme Court subsequently dismissed the plaintiff's appeal as untimely, thereby upholding the district court's judgment and sanction.
Why does Volker v. Nygaard matter for legal AI risk?
This record documents a Pro Se Litigant filing issue in SC North Dakota, with the listed outcome: Case dismissed with prejudice.
What does the public record establish about Volker v. Nygaard?
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.
Which source supports this Volker v. Nygaard summary?
The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.

Related matters

Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.

City of Dickinson v. HelgesonSC North Dakota · Feb 12, 2026same court · pro se + fake citationsCorey v. KennehSC North Dakota · Oct 22, 2025same court · pro se + fake citationsStokka v. StokkaSC North Dakota · May 7, 2026same court · pro se + fake citationsMohamed Ali v. Saeed OsmanNorth Dakota SC · Aug 6, 2026same jurisdiction · pro se + fake citationsRose v. Arts Bonita, Inc.M.D. Florida · Aug 12, 2026pro se + fake citations · same recorded tool: AI (implied, unspecified)Anish Sam Mathew v. Parv VermaE.D. Michigan · Aug 10, 2026pro se + fake citations · same recorded tool: AI (implied, unspecified)