North Dakota — AI Regulations

26 FEB 2026 · Court Case

Volker v. Nygaard

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.

Court: SC North DakotaParty: Pro Se Litigant

Harms: Hallucination in legal filings

12 FEB 2026 · Court Case

City of Dickinson v. Helgeson

Fabricated: Case Law | Court determined the cited State v. $44,140.00 U.S. Currency, 2003 ND 28 657 N.W.2d 829 is a nonexistent authority in Helgeson's brief. || Fabricated: Case Law | Court identified the citation State v. Clark, 2022 ND 85 999 N.W.2d 632 in Helgeson's brief as not corresponding to the asserted authority and found it fictitious as presented. || Fabricated: Case Law | Court found the cited State v. Rogers, 2006 ND 85 712 N.W.2d 841 listed by Helgeson did not match the authority he relied on and was among the fictitious citations. || Fabricated: Case Law | Court concluded the citation State ex rel. Stenehjem v. FreeEats.com Inc., 712 N.W.2d 828, 841 (N.D. 2006) as used by Helgeson was not an accurate existing authority and was treated as fictitious. || Fabricated: Case Law | Appellant cited 'State v. Clark, 2012 ND 135, 818 N.W.2d 739' among other offered authorities; the court determined several of these offered citations were fictitious or misleading. || Fabricated: Case Law | Appellant cited 'State ex rel. Olson v. City of Fargo, 250 N/A' in his brief; the court found the citation to be nonexistent after searching and listed a different, genuine Olson decision as unrelated. || Fabricated: Case Law | Appellant cited 'State v. $44,140.00 U.S. Currency, 2003 ND 28, 657 N.W.2d 829' which the court determined did not exist as offered and did not support his arguments. || Fabricated: Case Law | Appellant cited 'State v. $44,140.00 U.S. Currency, 2012 ND 176, 820 N.W.2d 697' as authority; the court found the offered citation to be fictitious and not the authority relied upon. || Fabricated: Case Law | Appellant cited 'State v. Clark, 2022 ND 85, 999 N.W.2d 632' in his brief but the court found the citation did not correspond to supporting authority as offered. || Fabricated: Case Law | Court found 'State ex rel. Olson v. City of Fargo, 250 N.W.2d 558 (N.D. 1977)' does not exist; court matched it to unrelated real reporters/titles and deemed it fictitious

Court: SC North DakotaParty: Pro Se Litigant

Fine: 500 USD

Harms: Hallucination in legal filings

12 FEB 2026 · Court Case

City of Dickinson v. Helgeson

Fabricated: Case Law | Court found 'State ex rel. Olson v. City of Fargo, 250 N.W.2d 558 (N.D. 1977)' does not exist; court matched it to unrelated real reporters/titles and deemed it fictitious. || Fabricated: Case Law | Court found 'State v. $44,140.00 U.S. Currency, 2003 ND 28 657 N.W.2d 829' as offered by Helgeson was nonexistent or misreferenced and did not support his claims. || Fabricated: Case Law | Court identified 'State v. $44,140.00 U.S. Currency, 2012 ND 176, 820 N.W.2d 697' in Helgeson's brief as a non-existent or incorrect citation and treated it as fictitious. || Fabricated: Case Law | Court noted 'State v. Clark, 2022 ND 85, 999 N.W.2d 632' as offered by Helgeson did not correspond to the cited authorities and was treated as a nonexistent/misleading citation. || Fabricated: Case Law | Court found 'State ex rel. Stenehjem v. FreeEats.com Inc., 712 N.W.2d 828, 841 (N.D. 2006)' in Helgeson's brief to be a fictitious citation that did not exist as cited.

Court: SC North DakotaParty: Pro Se Litigant

Fine: 500 USD

Harms: Hallucination in legal filings

22 OCT 2025 · Court Case

Corey v. Kenneh

Fabricated: Case Law | Corey's brief cited case law that the Court found led to different or no cases; Court concluded the citations were non-existent and could not support dismissal for mootness.

Court: SC North DakotaParty: Pro Se Litigant

Harms: Hallucination in legal filings

08 FEB 2024 · Policy / Guidance

State of North Dakota Artificial Intelligence Policy

Establishes policy for North Dakota's AI use to ensure safety, privacy, and ethical standards. Requires AI reliability, transparency, and accountability. Mandates risk management, privacy assessments, and compliance with legal frameworks. Directs NDIT to provide training and evaluate new AI technologies.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2ndit.nd.gov ↗

11 APR 2023 · Law / Act

An act to amend and reenact subsection 8 of section 1-01-49 of the North Dakota Century Code, relating to the definition of person; and to declare an emergency

Clarifies that artificial intelligence cannot qualify as a "person" for the purpose of North Dakota state law.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2ndlegis.gov ↗