Nuvola, LLC v. Wright
Minnesota District Court, County of Hennepin, Fourth Judicial District · Minn. Dist. Ct. (Hennepin Cnty.) · Minnesota bar guidance
Verified April 26, 2026
- Citation
- Nuvola, LLC v. Wright, No. 27-CV-HC-15-3802 (Minn. Dist. Ct., Hennepin Cnty. Nov. 20, 2025)
- Decided
- November 20, 2025
Summary
Defense counsel Frederic W. Knaak submitted a Memorandum in Support of Motion to Compel Arbitration containing multiple non-existent case citations generated by an unidentified AI program. Knaak admitted he provided the AI with researched authority, expected the AI to draft a brief citing those cases, and did not check the citations in the resulting work product before filing. Judge Laurie J. Miller discovered the fabricated citations during her own research while ruling on the motion and issued an Order to Show Cause.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,000
What sanction did the court impose?
$1,000 financial penalty payable to the court within 180 days, an order to deliver five educational presentations to lawyers or law students on the dangers of AI in legal practice within one year (one of which may be a published article), and referral to the Minnesota Office of Lawyers Professional Responsibility under Rule 8.3 of the Minnesota Rules of Professional Conduct.
Why does Nuvola, LLC v. Wright matter for law firms using AI?
Nuvola illustrates that even decades-long, discipline-free careers do not insulate counsel from sanctions when AI-generated citations go unchecked. Notable for a Minnesota state court: Judge Miller paired a modest $1,000 monetary penalty with a substantial public-education obligation (five CLE-style presentations) and a Rule 8.3 referral to the OLPR, signaling that competence under Rule 1.1 now extends to verifying AI work product. The order also faulted opposing counsel for failing to cite-check the adversary’s brief, framing citation verification as a duty owed by both sides.
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.