Missouri

Effective Date

Summary

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).