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North Dakota · state supreme court · 2026

Volker v. Nygaard

North Dakota Supreme Court, 26 February 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · N.D.

  1. Court. North Dakota Supreme CourtCOURT
  2. Level. state supreme courtLEVEL
  3. Date. 26 February 2026DATED
  4. Docket. No. No. 20250309DOCKET
  5. Judge. Tufte, Jerod E.JUDGE
  6. Reporter. 2026 ND 56CITE
  7. Documents. one document, 2 passages quoted belowON FILE
  8. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 26 February 2026 · source · PDF · 6 pages

20250309 Tufte, Justice. [¶1] Scott Volker appeals from a district court judgment dismissing his claims with prejudice as a Rule 11, N.D.R.Civ.P., sanction for repeatedly submitting fictitious, AI-generated case citations. Danielle Hough, formerly known as Danielle Nygaard, and Ahlaina Mohler moved to dismiss the appeal as untimely.

I [¶2] Volker commenced this action against Hough and Mohler, who moved to dismiss the complaint at the district court. During the hearing on the motion, the court warned Volker that his filings contained fictitious legal citations. Despite this warning, Volker filed additional briefs containing fictitious citations.

What the text mentions

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More from North Dakota Supreme Court, from North Dakota, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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