Kruse v. Karlen
Missouri Court of Appeals, Eastern District · Mo. Ct. App. E.D. · Missouri bar guidance
Verified April 24, 2026
- Citation
- Kruse v. Karlen, No. ED 111172 (Mo. Ct. App. E.D. Feb. 13, 2024)
- Decided
- February 13, 2024
Summary
Molly Kruse sued her former employer Jonathan R. Karlen for unpaid wages. The trial court granted summary judgment for Kruse. Karlen appealed. In his appellate brief, Karlen had hired an online consultant claiming to be a California-licensed attorney to prepare the brief. Karlen later stated the consultant had used AI to generate citations without his knowledge. Of the 24 case citations in the brief, only 2 were real; the remaining 22 were fictitious.
- AI tool:
- AI (unspecified)
- Sanction amount:
- $10,000
What sanction did the court impose?
The Missouri Court of Appeals dismissed the appeal due to fatal briefing deficiencies and imposed $10,000 in sanctions under Missouri Supreme Court Rule 84.19 (frivolous appeals). The court warned: 'We urge all parties before this Court, barred and self-represented alike, to be cognizant that we are aware of the issue and will not permit fraud on this Court.'
Why does Kruse v. Karlen matter for law firms using AI?
Kruse v. Karlen is the leading Missouri AI sanctions case in this tracker. The Eastern District Court of Appeals dismissed the appeal and assessed $10,000 in Rule 84.19 sanctions when 22 of 24 citations turned out to be fabricated, and an outsourced drafting arrangement did not shield Karlen from liability. The lesson for Missouri practitioners: hiring out a brief does not transfer the verification duty, and a court that finds itself reading fictitious citations will treat the filing as fraud rather than negligence.