Pro Se Litigant Sanctioned for Citations to AI-Generated Cases

The Case: https://www.courts.mo.gov/file.jsp?id=205455

Kruse v. Karlen et al., No. ED11172 (Mo. Ct. App. Feb. 13, 2024).

Appellant Karlen's appeal is dismissed due to "numerous fatal briefing deficiencies," including submission of AI-generated cases. In particlar, the court notes that "the overwhelming majority of citations are not only inaccurate but entirely fictitious." Slip op at 5.

The pattern in this case bears similarity to the S.D.N.Y. case that made the rounds last year--the citations are a mix of entirely plausible, but nonexistent, case names and some actual case names that "do not stand for the propositions asserted." Slip op at 6. The court also includes a nice table of (non-) authorities. Kudos to the law clerk(s) or other parties who had to chase all those down.

According to Appellant, an online consultant purportedly licensed in California prepared the brief (slip op at 8). Nonetheless, he certified compliance and so this dismissal comes with a $10,000 sanction.