Introduction
The Minnesota Court of Appeals affirmed the dismissal of Michael Kwabena Asiedu’s civil claims against Olmsted County and child-protection employees. It also upheld an award of attorney fees imposed after the district court found that Asiedu repeatedly cited caselaw inaccurately or cited cases that did not exist.
Relevant facts and procedural posture
Asiedu, representing himself, sued Olmsted County’s Health, Housing, and Human Services division and several child-protection employees. His amended complaint alleged that employees removed his 12-year-old child from school without a court order or emergency-removal findings, relied on false and unsubstantiated abuse allegations, disseminated a safety plan containing those allegations, restricted his access to the child and the child’s records, and refused to provide the plan and related records.
Because the district court dismissed the complaint for failure to state a claim, the Court of Appeals accepted the complaint’s allegations as true for purposes of reviewing that dismissal. The opinion did not treat those allegations as factual findings.
What the Court of Appeals decided
Qualified immunity
The court held that the individual employees were entitled to qualified immunity from Asiedu’s federal claim under 42 U.S.C. § 1983. Even accepting his allegations as true, the court concluded that he had not alleged the conscience-shocking conduct required for his substantive-due-process theory. The court also concluded that his complaint did not allege the notice-and-hearing deprivation needed to sustain a procedural-due-process claim.
Official and vicarious official immunity
The court also held that the employees were entitled to common-law official immunity from the state-law claims. It characterized the challenged child-protection decisions—including protective placement, creation and dissemination of the safety plan, and access to related information—as discretionary rather than ministerial acts. The complaint did not allege an improper motive sufficient to defeat official immunity. Because the employees were immune, the court extended vicarious official immunity to the county.
Sanctions for inaccurate authority
The district court used its inherent authority to sanction Asiedu after finding that he repeatedly misrepresented caselaw by citing real cases for incorrect legal principles or by citing cases that did not exist. The sanction consisted of respondents’ reasonable costs and attorney fees totaling $2,341.25.
At the district-court hearing, Asiedu acknowledged using artificial intelligence as a research tool and not verifying the accuracy of the caselaw because he was “doing this part time.” The Court of Appeals concluded that the record supported the district court’s finding of bad faith and that Asiedu had not met his burden to show that the district court abused its discretion.
AI use itself was not the sanctionable act; the sanction rested on repeated inaccurate authority, failure to verify it, and the district court’s finding of bad faith.
Why Justice-Denied is watching
The sanctions ruling directly concerns the accuracy of legal authority. It distinguishes two related failures: inventing authority and using real authority for a proposition it does not support. That distinction also appears in Justice-Denied’s broader discussion of verification and legal hallucinations in “When the Law Hallucinates.”
The opinion is also relevant to appellate procedure, due process, and official immunity. Its limits are equally important: the underlying claims were dismissed on immunity grounds, the allegations were not adjudicated as facts, and the sanctions decision was reviewed deferentially.
Source
Minnesota Court of Appeals opinion in Asiedu v. Eastlund, A25-2106 and A26-0532 (filed September 8, 2026).
