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Incident Tracker / United States (state)

Kruse v. Karlen, No. ED111172 (Mo. Ct. App., E.D.)

·Missouri Court of Appeals, Eastern District·US-STATESanctions

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.

Court
Missouri Court of Appeals, Eastern District
Date
2024-02-13
Who used the AI
Not recorded
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.
Outcome
Sanctions
Penalty
US$10,000
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-16

What was fabricated or misused

  • Smith v. ABC Corporation, 321 S.W.3d 123 (Mo. App. 2010) — fictitious citation
  • Jones v. XYZ Company, 450 S.W.2d 789 (Mo. 2012) — fictitious citation
  • State ex rel. Johnson v. Clark, 499 S.W.3d 413 (Mo. 2016) — fictitious citation using a real case name
  • Brown v. Smith, 456 S.W.2d 345 (Mo. 1970) — fictitious citation using a real case name
  • Warren v. White, 678 S.W.2d 768 (Mo. App. 1984) — fictitious citation
  • Holmes v. Johnson, 890 S.W.2d 334 (Mo. App. 1994) — fictitious citation
  • Winters v. Kim, 903 S.W.2d 838 (Mo. App. 1995) — fictitious citation
  • White v. Smith, 789 S.W.2d 45 (Mo. 1989) — fictitious citation using a real case name
  • Brown v. Johnson, 925 S.W.2d 456 (Mo. App. 1996) — fictitious citation using a real case name
  • State ex rel. Pioneer Hi-bred Int’l, Inc. v. Craig, 940 S.W.2d 343 (Mo. 1997) — fictitious citation
  • Weber v. City of Cape Girardeau, 447 S.W.3d 885 (Mo. App. 2014) — fictitious citation
  • Hall v. Landscape Servs., Inc., 456 S.W.3d 60 (Mo. App 2015) — fictitious citation
  • Anderson v. Rapid Roberts, Inc., 539 S.W.3d 367 (Mo. App. 2017) — fictitious citation
  • Baker v. St. Louis Symphony Orchestra, 439 S.W.3d 750 (Mo. App. 2014) — fictitious citation
  • Hughes v. Cintas Corp., 501 S.W.3d 34 (Mo. App. 2016) — fictitious citation
  • Huett v. Dollar Tree Stores, Inc., 913 S.W.2d 229 (Mo. App. 1995) — fictitious citation
  • Great Southern Bank v. Edie, 329 S.W.3d 622 (Mo. App. 2010) — fictitious citation
  • City of St. Louis v. Sprint Spectrum L.P., 475 S.W.3d 270 (Mo. App. 2015) — fictitious citation using a real case name
  • State ex rel New Madrid County Juvenile Office v. Ramsey, 361 S.W.3d 919 (Mo. App. 2012) — fictitious citation
  • State ex rel. Platte County v. Clemmons, 862 S.W.2d 877 (Mo. banc 1993) — fictitious citation
  • Copeland v. Mercantile Bank, 827 S.W.2d 507 (Mo. banc 1992) — fictitious citation
  • Schaffer v. County of Cape Girardeau, 342 S.W.3d 241 (Mo. banc 2011) — fictitious citation
  • Rule 87.07 statement about trial-court review of all evidence — erroneous; the relevant rule was Rule 78.07 and concerned after-trial motions
  • Rule 55.23 statement about damages in default judgments — erroneous; the rule was repealed in 2018 and concerned written instruments

What the court said

“Due to numerous fatal briefing deficiencies under the Rules of Appellate Procedure that prevent us from engaging in meaningful review, including the submission of fictitious cases generated by artificial intelligence (“A.I.”), we dismiss the appeal.”
Missouri Court of Appeals, Eastern District, p. 1
“Only two out of the twenty-four case citations in Appellant’s Brief are genuine.”
Missouri Court of Appeals, Eastern District, p. 5
“Neither the case nor the specific quote it purports to contain exist in reality.”
Missouri Court of Appeals, Eastern District, p. 5
“Appellant is hereby ordered to pay Respondent damages towards appellate attorneys’ fees in the amount of $10,000.”
Missouri Court of Appeals, Eastern District, p. 12

Timeline

  1. Opinion recorded that appellant filed the appeal pro se from final summary judgment.
  2. Court itemized twenty-two inaccurate case citations in the appellate brief.
  3. Court dismissed the appeal and ordered $10,000 in Rule 84.19 damages.

Why this case matters

Kruse is an early state-appellate counterpart to Park v Kim. The filing was not by a lawyer, but the court applied the same verification principle to a self-represented appellant who used a paid online consultant. The volume of false authority was far above Dukuray and Morgan: twenty-two of twenty-four case citations were not genuine, plus rule and statute errors. The $10,000 Rule 84.19 award shows a hallucinated brief can convert an already deficient appeal into a frivolous-appeal damages order.

Practice note

A self-represented appellant remains responsible for every citation filed in the appellant's name. Before submitting a brief, the filer should check the appendix, statement of facts, points relied on, table of authorities and each citation against the court rules. Paid consultants should provide source opinions, and any AI-assisted draft should be verified before signature.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

Similar incidents on the record

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Kruse v. Karlen, No. ED111172 (Mo. Ct. App., E.D.)”, safelegalai.com/tracker/kruse-v-karlen (accessed 2026-09-16). Data: CC BY 4.0.

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