Volker v. Nygaard
SC North Dakota · Feb 26, 2026
- Jurisdiction
- state
- Court
- SC North Dakota
- Record ID
- volker-v-nygaard-2026-02-26
- Observed outcome
- The district court dismissed the case with prejudice as a Rule 11 sanction; the Supreme Court dismissed the appeal as untimely.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in SC North Dakota, with the listed outcome: Case dismissed with prejudice.
Failure modes and consequences
- Pro Se
- Fake Citations
- Other
- Trial
- Case Dismissed
- AI attribution
- Explicitly Recorded
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- Not recorded
- 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.
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 explicitly refers to the citations as AI-generated.
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.
- Escalate and correct a suspect filing promptly, with a documented response.