Kruse v. Karlen, No. ED111172 (Mo. Ct. App., E.D.)
sanctions
In the Missouri Court of Appeals, Eastern District, a self-represented appellant's brief contained 22 fictitious citations out of 24, generated by an AI application used by a consultant he had hired. The court dismissed the appeal for briefing deficiencies and ordered him to pay $10,000 in damages for a frivolous appeal.
- Date of decision/order
- 2024-02-13
- Court
- Missouri Court of Appeals, Eastern District
- Jurisdiction
- US-STATE
- AI tool
- Not identified in the record
- Conduct
- A self-represented appellant filed a brief in which 22 of 24 case citations were fictitious AI-generated hallucinations, produced by an out-of-state legal consultant he had hired who used an AI application. The court found the brief flagrantly deficient.
- Consequence
- USD 10,000
Sources
Cite this incident
SafeLegalAI Global Legal AI Incident Tracker, "Kruse v. Karlen, No. ED111172 (Mo. Ct. App., E.D.)", safelegalai.com/tracker/kruse-v-karlen (accessed 2026-07-16). Data: CC BY 4.0.