Courts on AI / Fabricated or misquoted citations
Boatner v. Hickerson
Missouri Court of Appeals · State appellate courts · MO · · No. ED113978 · order
On 2026-06-02, in Boatner v. Hickerson, Missouri Court of Appeals imposed a $10,000 monetary sanction for the defective legal authorities. A self-represented appellant cited Davis v. Bess even though the court found the authority did not exist. The monetary component was $10,000.
- Disposition
- The court imposed a $10,000 monetary sanction for the defective legal authorities.
- Recorded conduct
- A self-represented appellant cited Davis v. Bess even though the court found the authority did not exist. — outcome: sanctions; actor: litigant in person; $10,000
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
Boatner’s appeal violates several Missouri Supreme Court Rules, including the briefing requirements of Rule 84.04, and her amended brief includes fictitious cases generated by artificial intelligence (“A.I”), which prevent this Court from engaging in meaningful review. Accordingly, the appeal is dismissed. Additionally, given the frivolousness of the appeal, this Court awards $10,000 in damages to Hickerson, pursuant to Rule 84.19. Factual and Procedural Background On March 10, 2025, Boatner, acting pro se, filed a “Petition to Quiet Title” against Hickerson. Therein, Boatner sought to quiet title for a property on Capitol Drive in St. Louis County (“Property”). Because personal service of process was not successful on Hickerson, Boatner filed an application for service by publication. The trial court entered an order for service by publication. Then, on July 14, 2025, the trial court entered a default judgment in favor of Boatner.2 Rule 54.20(e) sets forth the requirements for proving service by publication, stating: Service by publication shall be proved by an affidavit showing the dates upon which and the newspaper in which the notice was published.
Authorities cited in the passage: Rule 84.04 · Rule 84.19 · Rule 54.20(e)