Osborne Properties Limited Partnership v. Mohamed

What sanction did the court impose?

Judge Lois R. Conroy held that Ahmed "violated Minn. R. Civ. P. 11.02(b) and Minnesota Statutes § 549.211, subd. 2(2), when he twice submitted a fake, hallucinated case in his briefing." The order struck the false and non-existent citations, corrected the inaccurate ones, and ordered Ahmed to pay a $5,000 penalty into court within 180 days, stating that "[t]his penalty is imposed on Attorney Ahmed and not his client." The court noted that Ahmed had provided "no cause for the nature of his actions, no corrections to his citations," and had not taken responsibility, and it said it was obligated to inform the Minnesota Lawyers Professional Responsibility Board, to which it would send the brief and the order. The court reasoned that proffering fake law without verifying it "can be seen in no way other than an effort to mislead the Court, regardless of whether the party acted deliberately." The order does not affect the judgment. On May 5, 2026, at Ahmed's request, the court amended the payment term to $500 a month beginning in June 2026, leaving the $5,000 penalty unchanged.

Why does Osborne Properties Limited Partnership v. Mohamed matter for law firms using AI?

Osborne is a Hennepin County sanctions order entered after the merits were already decided. Plaintiff’s counsel raised the problem at the summary judgment hearing and followed up with a letter listing the errors; the court gave defense counsel Faisal Ahmed the chance to respond orally and then in writing, and he filed nothing. After granting summary judgment for the landlord, the court issued a separate order finding two nonexistent cases, a quotation the cited rule does not contain, and two garbled citations in Ahmed’s opposition memorandum.

The court grounded the sanction in both Minn. R. Civ. P. 11.02(b) and Minn. Stat. § 549.211, subd. 2(2), relying on the Minnesota Tax Court’s holding in Delano Crossing that “the inclusion of citations to non-existing cases (or other legal authorities) is a violation of Rule 11.02(b).” It surveyed the warnings Minnesota lawyers had already received about AI research, including the Minnesota Supreme Court’s November 2024 order in Harris v. Lindell and ABA Formal Opinion 512, but it did not find that Ahmed himself used AI; its holding is that he submitted “a fake, hallucinated case” twice. The court described the violations as “egregious” and emphasized how easily they could have been avoided.

The sanction ran against the lawyer, not the client: a $5,000 penalty into court, with the false citations struck and the inaccurate ones corrected, and a statement that the court would inform the Lawyers Professional Responsibility Board. In May 2026 the court let Ahmed pay the penalty at $500 a month. Firms documenting compliance may wish to consider that, here, the court noted counsel’s silence after opposing counsel flagged the citations, and that the consequence followed even though the case itself was already over on the merits; the order notes the case did not end by voluntary dismissal or settlement, and a footnote quotes the statute’s limit on court-initiated monetary sanctions in cases that do.