The sanctions record · Minnesota Court of Appeals, 2026
Asiedu v. Eastlund
Michael Kwabena Asiedu v. Terry Eastlund, et al., Nos. A25-2106 and A26-0532 · Larson, Judge, for the court; Ross, Presiding Judge, and Beane, Judge · filed 8 September 2026, affirmed · nonprecedential
Page verified 9 September 2026. Opinion read in full, eleven pages, at the Minnesota State Law Library’s archive of Court of Appeals opinions. Nonprecedential except as provided by Minn. R. Civ. App. P. 136.01, subd. 1(c).
An appellate affirmance of an AI citation sanction against a self-represented litigant. The Olmsted County District Court, using its inherent authority, ordered the appellant to pay the respondents’ reasonable costs and attorney fees of $2,341.25 after finding that he cited case law in a manner that was “either misleading, false, [or] non-existent”. At the hearing he admitted using artificial intelligence as a research tool and not checking the citations because he was “doing this part time”. The Court of Appeals affirmed: “We hold pro se parties to the same standard as attorneys when filing documents in court.”
The record
- CourtMinnesota Court of Appeals, on appeal from Olmsted County District Court, File No. 55-CV-25-2902
- PanelRoss, Presiding Judge; Larson, Judge, who wrote; Beane, Judge
- CaseNos. A25-2106 and A26-0532, consolidated. Nonprecedential opinion
- Filed8 September 2026. Affirmed
- PartySelf-represented appellant, Michael Kwabena Asiedu, suing a county child protection division and two of its employees
- ToolArtificial intelligence, not named. Admitted at the district court hearing as a research tool used to draft his filings
- Amount$2,341.25, the respondents’ reasonable costs and attorney fees, imposed under the district court’s inherent authority and affirmed
- StandardAbuse of discretion; the appellant bore “the difficult burden” of showing that no reasonable person would agree with the sanction
- MeritsComplaint dismissed under Rule 12.02(e) on qualified, official and vicarious official immunity; dismissal affirmed
What the court found
The district court found that the appellant “repeatedly misrepresented caselaw, either by citing a case for the wrong legal principle or citing non-existent cases”, and that in doing so he “did not conduct himself in accordance with the promises he made to the court when signing his documents”. It concluded the citations misled the court, citing Garner v. Kadince, Inc. (Utah Ct. App. 2025): “A fake opinion is not ‘existing law’ that can support a party’s legal contention.”
The Court of Appeals read that record as a finding of bad faith, which is what inherent-authority fee sanctions require, and held the appellant had not met his burden to show an abuse of discretion.
“We hold pro se parties to the same standard as attorneys when filing documents in court.”
Why it is on this list
Most AI citation sanctions on this record are trial-level orders. This one was tested on appeal and survived, on a record where the sanctioned party was not a lawyer and the explanation offered was lack of time. Neither the status nor the explanation moved the court.
The lesson for the next filing
The signature was the promise. The check behind it did not happen, and nothing could show otherwise.
Regulayer creates checkable evidence of who approved exact words and when. It does not do the checking. It shows that the checking happened, and who stood behind it.
Generate the certification → · Verify a sealed record free →
Sources
- Asiedu v. Eastlund, Nos. A25-2106, A26-0532 (Minn. App. Sept. 8, 2026), the opinion, eleven pages, at the Minnesota State Law Library archive
Related
- The full sanctions record
- State ex rel. Schnell v. Richardson, decided the same day in Missouri
- State of Hawaiʻi v. Presti, another appellate court on nonexistent citations
Verified 9 September 2026 against the court’s opinion, read in full. Information, not legal advice.
Information, not legal advice. Every entry is verified against the court’s own document or contemporaneous reporting; where a source is reporting rather than the document, we say so.