Courts on AI / Fabricated or misquoted citations
Whitehead v. Moore
Missouri Court of Appeals, Western District · State appellate courts · MO · · No. WD88216 · opinion
The Missouri Court of Appeals dismisses self-represented father Zackery Moore’s family-access appeal because he did not supply the record needed for review. A footnote says his brief also contained two nonexistent reporter citations and one misrepresented holding, independently supporting dismissal.
- Disposition
- The court dismissed the self-represented father's appeal for failure to provide a required record.
- Recorded conduct
- Self-represented appellant’s brief cited two cases that did not exist in the cited reporters and misrepresented another case’s holding. — outcome: dismissal; actor: litigant in person
- 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.
Therefore, we dismiss Father’s appeal for failure to provide this Court with the required record on appeal necessary to resolve the questions raised in his appeal. ... There are numerous other briefing deficiencies with Father’s appellate brief that would also independently support dismissal of Father’s appeal. ... Father’s brief includes two citations to cases that do not exist in the reporter he cites, and he additionally cites one case for a legal proposition that cannot be reasonably inferred from that case. Citing non-existent case law or misrepresenting the holdings of an existing case is “a flagrant violation of the duties of candor Appellant owes to this Court,” which warrants dismissal of an appeal. See Kruse v. Karlen, 692 S.W.3d 43, 52 (Mo. App. E.D. 2024).
Authorities cited in the passage: Kruse v. Karlen, 692 S.W.3d 43 (Mo. App. E.D. 2024) · Missouri Rule 84.04
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