Missouri

Effective Date

Summary

In Quraishi v. Creative Planning LLC, No. 4:25-CV-00105, the court found that the plaintiff likely used “an artificial intelligence tool” to cite case law in support of her service deadline argument because she included “cites to two cases that do not exist” or that refer to “completely different [and unrelated] cases.” Although no sanctions were imposed, Judge Bough warned against any further inclusion of false citations. 

The Court of Appeals of Missouri (Eastern District, Division Three) recently issued a decision in Stevens v. BJC Health Sys., No. ED112759, at *4 n.1 (Mo. App. E.D. Mar. 18, 2025) affirming the dismissal of an appeal where the appellant failed to prove legal error in part because their brief “contains citations to six cases that this Court was unable to locate” and “suggests the use of artificial intelligence [for] drafting” the brief. Relying in part on a 2024 decision (in which the Missouri Court of Appeals, Eastern District dismissed an appeal in part due to “submission of fictitious cases generated by artificial intelligence”), the court ruled that “in light of [AI’s] increasing prevalence, we warn litigants that using [AI] to draft a legal document may lead to sanctions if the user fails to perform a critical review” of the final product to ensure no fictitious citations are present. Although the decision does not use the term “generative AI,” the cases relied upon and the manner in which AI was purportedly used indicate that the court’s ruling is specific to AI used for “drafting” legal filings in a manner which results in errors, and is thus likely targeted at Gen AI.

This Notice on the Court’s website reminds attorneys and self-represented litigants that they will be held responsible for the contents of their filings “including any portion generated with artificial intelligence,” and cites Fed. R. Civ. P. 11(b).

In Kruse v. Karle, 692 S.W.3d 43 (Mo. Ct. App. 2024), the appellant filed a brief with nearly all fictitious citations, some of which had “potentially real case names,” which the court described as “presumably the product of algorithmic serendipity.” The appellant apologized for these errors and explained he was unaware that the “consultant” who held himself out as an attorney and prepared the briefing would use “artificial intelligence hallucinations.” While acknowledging that pro se parties face unique challenges in litigation, the court noted that the appellant made more than “minor” errors and did not take the opportunity to remediate them after the respondent expended resources to identify the fictitious citations. As such, the court ordered the appellant to pay $10,000 of the respondent’s attorneys’ fees stemming from his violation of Missouri court rules regarding certification of compliance.