The North Dakota Supreme Court affirmed a district court's designation of Seth Neil Helgeson as a vexatious litigant and imposed $500 in sanctions against him for citing fictitious cases in his appellate brief, according to a decision issued in *City of Dickinson v. Helgeson* (N.D. 2026).
The case arose in March 2025 when Helgeson was stopped and cited for failing to display license plates in violation of Dickinson Municipal Code § 58-705. The citation was transferred from municipal to district court for a jury trial, where Helgeson was ultimately found in violation of the municipal ordinance.
The district court subsequently designated Helgeson as a vexatious litigant, a legal classification that restricts a person's ability to file future lawsuits without court permission. Helgeson appealed this designation to the state supreme court, challenging both the district court's jurisdiction to make such a determination and arguing that the designation violated his constitutional rights.
Justice Crothers, writing for the court, rejected Helgeson's jurisdictional challenge. The court held that the district court did not clearly err in designating Helgeson as a vexatious litigant. According to the opinion, the required findings, filings, and notices for identification of a vexatious litigant provide sufficient procedural safeguards to prevent constitutional violations.
The court explained that vexatious litigant statutes are designed to protect the judicial system from individuals who repeatedly file frivolous or harassing lawsuits. These designations typically require courts to make specific findings about a person's litigation history and pattern of conduct before restricting their access to the courts.
In affirming the vexatious litigant designation, the supreme court found that the procedural requirements had been met and that Helgeson's constitutional rights were adequately protected through the existing safeguards built into the process.
However, the most notable aspect of the case involved serious allegations of misconduct in Helgeson's appellate brief. The City of Dickinson claimed that Helgeson's brief contained citations to fictitious cases and requested that the court impose sanctions, specifically ordering Helgeson to pay the city's attorney's fees.
The court found merit in the city's allegations, determining that the citation to non-existent cases in an appellate brief constitutes a violation of North Dakota Rule of Appellate Procedure 28(l). This rule governs the content and form of appellate briefs and requires accuracy in legal citations and authorities.
Justice Crothers wrote that such violations expose the filing party to the imposition of sanctions for their misconduct. The court noted that citing non-existent cases undermines the integrity of the judicial process and wastes judicial resources as courts and opposing parties spend time attempting to locate and verify fictitious authorities.
Rather than ordering Helgeson to pay the city's full attorney's fees as requested, the court imposed a $500 sanction. This monetary penalty serves both as punishment for the misconduct and as a deterrent to prevent similar violations in the future.
The case highlights the importance of accuracy and honesty in legal briefs and the serious consequences that can result from attempting to mislead courts with fictitious authorities. Legal practitioners have a duty of candor to tribunals, and violations of this duty can result in sanctions, disciplinary action, and damage to professional reputation.
Vexatious litigant designations are relatively rare but serve an important function in preventing abuse of the court system. Individuals designated as vexatious litigants typically must obtain court permission before filing new lawsuits and may be required to post bonds to cover potential costs if their cases are deemed frivolous.
The underlying license plate violation that sparked this lengthy legal process was classified as a noncriminal violation under the Dickinson Municipal Code. Such violations typically result in fines rather than criminal penalties, but the case demonstrates how even minor infractions can escalate into complex legal proceedings when defendants choose to challenge them through multiple levels of appeal.
The decision in *City of Dickinson v. Helgeson* reinforces the authority of district courts to make vexatious litigant determinations and emphasizes the severe consequences that can result from filing false or misleading information with appellate courts. The $500 sanction imposed by the supreme court serves as a reminder that the legal system has mechanisms to address and punish misconduct by litigants and their representatives.
This case may serve as precedent for future vexatious litigant determinations in North Dakota and demonstrates the court's willingness to impose sanctions for violations of appellate procedure rules. The decision was issued as case number 20250340 and represents a comprehensive affirmation of lower court authority while maintaining standards for appellate practice.