Appellate and Complex Litigation Blog
February 26, 2024
Lawyerless Appellant Takes a Bad Trip in Missouri: AI Hallucinations Result in $10,000 Sanction for Frivolous Appeal
Earlier this month, Judge Kurt Odenwald on behalf of the Missouri Court of Appeals, Eastern District penned Missouri’s first appellate dismissal and award of sanctions for a brief that cited bogus cases generated by artificial intelligence—a phenomenon commonly referred to as “Artificial Intelligence Hallucinations.” Kruse v. Karlen, Case No. ED111172 (Mo. App. E.D. Feb 13, 2024). Below we discuss what happened in the case, how it illustrates the remarkable limitations of AI, and the risk of trying to work inside the legal system without a lawyer.