Hayes v. Miller

How did the court address the AI-related conduct?

In an opinion by Judge Lay (Presiding Judge Wright and Judge Hamilton concurring), the court held that the trial court erred in entering judgment for Miller III, who was not a party to the suit, and vacated the judgment in his favor on the unjust enrichment counterclaim under Rule 84.14 rather than remanding. That holding was dispositive, so the court did not reach Hayes's other two points. The court imposed no sanction and issued no warning or referral in connection with the nonexistent cases; it mentioned them only in a footnote to its procedural history.

Why does Hayes v. Miller matter for law firms using AI?

Hayes is a short item in a property dispute that turned on who was a party. The Eastern District vacated a money judgment for John Miller III because the ejectment suit had been brought against John Miller, Jr., and Miller III was never made a party, even though he signed the answer and testified at trial.

The citation issue appears only in the procedural history. Describing Hayes’s post-trial motion, the court added in a footnote that “Miller III’s response to the motion to amend contained several citations to nonexistent cases.” The opinion does not name the cases, does not mention artificial intelligence, does not identify who drafted the response, and takes no action on the point.

Firms documenting compliance may wish to consider that a trial-court filing can be described in an appellate opinion. Here citations in a post-trial response became part of the court’s account of the case, though they had no bearing on the result.