Appellate and Complex Litigation Blog

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.

Several months ago, shortly before a personal injury trial was set to begin in the Circuit Court of the City of St. Louis, one of our firm’s clients retained Appellate Team Leader Tim Sansone to attend the trial and work with trial defense counsel to preserve important issues for any future appeal.