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Incident Tracker

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.