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Nuvola, LLC v. Wright

Minnesota District Court, County of Hennepin, Fourth Judicial District · Minn. Dist. Ct. (Hennepin Cnty.) · Minnesota bar guidance

Court sanction

Verified September 30, 2026

Citation
Nuvola, LLC v. Wright, No. 27-CV-HC-15-3802, Order on Rule 11 Sanctions and Referral to Lawyers Professional Responsibility Board (Minn. Dist. Ct., Hennepin Cnty. Nov. 20, 2025) (Miller, J.)
Decided
November 20, 2025

Summary

In a tenant holdover dispute, defense counsel Frederic W. Knaak filed a memorandum in support of a motion to compel arbitration that cited multiple non-existent cases. The court found them while reviewing the briefs after the hearing and issued an order to show cause. In a declaration, Knaak admitted that he used generative AI to draft the memorandum; he claimed to have provided personally researched case law to the AI program and said he did not check or verify the citations in the AI-generated work product. Judge Laurie J. Miller found that he violated Minn. R. Civ. P. 11 and Minn. Stat. section 549.211 by failing to check the AI-generated citations before submitting them.

AI tool:
Unidentified generative AI program (counsel "admitted that he used generative artificial intelligence (AI) to draft his memorandum")
Sanction amount:
$1,000
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

What sanction did the court impose?

The court ordered Knaak to pay a $1,000 penalty into court within 180 days (imposed on counsel, not the client), to conduct five presentations to lawyers or law students on the dangers of using AI in the legal profession within one year (a published article may count as one), and referred Knaak under Rule 8.3 of the Minnesota Rules of Professional Conduct to the Minnesota Lawyers Professional Responsibility Board. The court also found opposing counsel's failure to check the cited cases "troubling" but not sanctionable, reminding both sides of the obligation to cite-check the other side's cases.

Why does Nuvola, LLC v. Wright matter for law firms using AI?

Nuvola shows a Minnesota trial court pairing a modest penalty with a public-education sanction. The court found counsel’s contrition “genuine” and did not think a large monetary sanction would add much deterrence, but concluded that “imposing no monetary sanction at all would minimize the serious nature of the violation.” It ordered five presentations on the dangers of AI in legal practice, citing Rule 11’s aim of deterring “others similarly situated,” and referred counsel to the Lawyers Professional Responsibility Board. The order also addresses opposing counsel, who had not checked the citations in the brief he was answering: “The Court should not be left as the last line of defense against citations to fictional cases in briefs filed with the court.”

Sources

Primary sources

Further reading

Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.

Unverified claims:
  • The cited URL is a third-party tracker's mirror of a Lexis reprint of the order (2025 Minn. Dist. LEXIS 5940). The court's own copy is in Minnesota Court Records Online (search court file no. 27-CV-HC-15-3802 at the cited MCRO case-search page), which has no stable per-document URL; the entry was verified against the MCRO copy (see reviewer).