Minnesota

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Minn. Tax Court – Judge Jane N. Bowman, Chief Judge Bradford S. Delapena, and Hon. Beverly J. Luther Quast  5/29/2025 Generative AI   Generative AI Usage In Delano Crossing 2016, LLC v. Cnty. of Wright, 2025 Minn. Tax LEXIS 23, the defendant submitted AI-generated case citations in its motion for summary judgment before the tax court. Defendant’s counsel claimed the final brief that contained AI-generated citations was “never intended to be the final product” yet could not identify “‘any other documents containing [her] research.’” The court found that the defendant’s use of AI violated Rule 11.02(b) of the Minnesota Rules of Civil Procedure for submitting nonexistent or frivolous arguments, as “fake case citations cannot support any legal claim” and are “inherently misleading.” The court rejected counsel’s defense that all asserted claims could be supported by existing precedent, as parties have “an affirmative duty to investigate the ‘legal underpinnings of a pleading.’” The court declined to sanction defendant’s counsel and found that denying the motion for summary judgment on the merits was a sufficient deterrent from solely relying on GenAI for case citations in future filings. The court did, however, send a copy of this opinion and various other filings to the Minnesota Lawyer’s Professional Responsibility Board, as the use of false case citations “reasonably raises questions as to a lawyer’s honesty, trustworthiness, and/or fitness as a lawyer.”
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences