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AI failures · Fabricated content

Kruse v. Karlen — Missouri Court of Appeals Sanctions Self-Represented Appellant for AI-Fabricated Citations

Verified Checked against its sources on 3 sources quoted

Where it happened
Missouri, United States
Organization
N/A (individual self-represented litigant)
Date
February 13, 2024 (opinion filed)
Function
Legal
Where it happened
Appellate brief drafting (by a hired online consultant, per the appellant)
System
Unspecified generative AI (per the appellant's account)
Technology
Generative AI
Type of failure
Fabricated content
Caught by
The opposing party, A court

Summary

Jonathan Karlen, a business owner representing himself in an appeal from an unpaid-wages judgment, filed an appellate brief in which only two of 24 case citations were genuine; he told the court an online consultant presenting as a California-licensed lawyer had prepared it. The Missouri Court of Appeals, Eastern District (No. ED111172), dismissed the appeal as frivolous and ordered him to pay $10,000 in damages toward the respondent's attorneys' fees.

Consequence

  • Appeal dismissed as frivolous; appellant ordered to pay $10,000 in damages toward the respondent's attorneys' fees.

Who caught it The opposing party, A courtFound outside the organization

Analysis

What could have been done

Oversight of suppliers' AI use

Suppliers' use of AI is disclosed, contracted for and checked.

The appellant, a business owner representing himself, filed a brief that he said had been prepared by a hired online consultant presenting as a California-licensed lawyer, using generative AI by his account.

Checking AI output against its sources

Every factual element of AI output (citations, figures, quotations) is checked against its source before reliance.

Only two of the 24 case citations in the brief as filed were genuine.

What would likely have prevented it

  • Before engaging an outside preparer for a filing or other document filed in one's own name, confirm any claimed professional licence with the body that issues it and ask whether and how AI tools will be used.
  • Check the citations in delivered work against an authoritative source before signing or filing it, since the consequences of the filing fall on the filer.

What would likely have caught it earlier

  • On receipt of outsourced work, check a sample of its citations; with only two of 24 genuine, almost any sample would likely have exposed the problem before the respondent's motion to strike did.

Related reading Treat AI Output Like an Unsupported Journal EntryMost Documented AI Failures Were Found by Someone Else

Key dates

  1. February 13, 2024Event
  2. October 16, 2026Checked against sources
  3. October 18, 2026Checked against sources
  4. October 21, 2026Checked against sources

Developments are added when the record is reviewed. Next review: October 16, 2027.

Evidence

Each passage is quoted from its source. The quoted passages are re-checked against the live pages every month.

  1. First, the court dismissed his appeal. Then, deeming his appeal frivolous, it ordered him to pay $10,000 in damages towards his opponent’s attorneys’ fees.

    Supports: Sanction: dismissal and $10,000 damages toward fees

    Not Again! Two More Cases, Just this Week, of Hallucinated Citations in Court Filings Leading to Sanctions LawSites (Robert Ambrogi) Reporting or analysis

  2. A three-judge panel for the Eastern District of the Missouri Court of Appeals determined that Jonathan Karlen, a business owner representing himself in an unpaid wages lawsuit in a state trial court, cited only two genuine legal precedents out of the 24 citations in his appeals brief.

    Supports: Court, party, self-representation, 2 of 24 citations genuine

    Missouri Businessman Fined for False AI-Created Case Citations Bloomberg Law Reporting or analysis

  3. "dateFiled": "2024-02-13", "dateReargued": null, "dateReargumentDenied": null, "docketNumber": "ED111172"

    Supports: Opinion filing date and docket number (court-record index; the court's own site blocks automated readers)

    CourtListener opinion search: Molly Kruse v. Jonathan R. Karlen CourtListener (Free Law Project) Tracker or database

Suggested citation. Eminence Scan, “Kruse v. Karlen — Missouri Court of Appeals Sanctions Self-Represented Appellant for AI-Fabricated Citations”, Eminence Growth Solutions, last verified October 16, 2026, https://eminencegrowthsolutions.com/tools/eminence-scan/record/fail-007/.

Using our research: you may read and quote Eminence Scan with credit to “Eminence Scan, Eminence Growth Solutions” and a link; all other rights reserved. Terms: Using our research.

Spotted an error, or a development we have missed? Report a correction. How we check records: research methodology.