E.D. Mo. and W.D. Mo.: Judge's Requirements, Section XVIII (Mandatory Certification Regar…
Hon. Joshua M. Divine, U.S. District Judge · U.S. District Courts for the Eastern and Western Districts of Missouri
Verified September 30, 2026
- Citation
- Judge's Requirements, Section XVIII (Mandatory Certification Regarding Generative Artificial Intelligence) (Hon. Joshua M. Divine, E.D. Mo. and W.D. Mo.)
- Order date
- June 2026
Summary
'All attorneys and pro se litigants appearing before the Court must file a certificate on the docket, together with their notice of appearance, attesting either that no portion of any filing will be drafted by generative artificial intelligence (such as ChatGPT, Harvey.AI, or Google Bard) or that any language drafted by generative artificial intelligence will be fully checked for accuracy by a human being, using print reporters or traditional legal databases.'
What does the order require?
- 'All attorneys and pro se litigants appearing before the Court must file a certificate on the docket, together with their notice of appearance, attesting either that no portion of any filing will be drafted by generative artificial intelligence (such as ChatGPT, Harvey.AI, or Google Bard) or that any language drafted by generative artificial intelligence will be fully checked for accuracy by a human being, using print reporters or traditional legal databases.'
- The certificate is filed under the CM/ECF 'notices' event titled 'AI notice.'
- Pro se litigants 'must also file this certification and are equally barred from using artificial intelligence without fully checking each assertion and case citation for accuracy. The Court will not grant leniency to pro se litigants.'
- 'The Court may issue sanctions for submitting non-existent caselaw or for misrepresenting a case. These sanctions can include fines, striking a document, and dismissing a case.'
- The sample certification in footnote 2 extends the check to 'quotations, citations, paraphrased assertions, and legal analysis' and states that any attorney who signs a filing 'will be held responsible for the contents thereof according to applicable rules of attorney discipline, regardless of whether generative artificial intelligence drafted any portion of that filing.'
Practice areas: federal civil, federal criminal
What the requirement says
Judge Joshua M. Divine (E.D. Mo. and W.D. Mo.), Judge’s Requirements (June 2026), Section XVIII. The section, titled “Mandatory Certification Regarding Generative Artificial Intelligence,” requires every attorney and pro se litigant to file a certificate on the docket with their notice of appearance. The certificate attests “either that no portion of any filing will be drafted by generative artificial intelligence (such as ChatGPT, Harvey.AI, or Google Bard) or that any language drafted by generative artificial intelligence will be fully checked for accuracy by a human being, using print reporters or traditional legal databases.” The CM/ECF event is under “notices” and titled “AI notice.”
The section applies the same rule to self-represented litigants, who “are equally barred from using artificial intelligence without fully checking each assertion and case citation for accuracy,” and states that “The Court will not grant leniency to pro se litigants.” It warns that the Court “may issue sanctions for submitting non-existent caselaw or for misrepresenting a case,” including “fines, striking a document, and dismissing a case.”
Footnote 2 supplies sample language. It certifies compliance with all of Judge Divine’s judge-specific requirements, extends the human check to “quotations, citations, paraphrased assertions, and legal analysis,” and acknowledges that a signing attorney “will be held responsible for the contents thereof according to applicable rules of attorney discipline, regardless of whether generative artificial intelligence drafted any portion of that filing.”
How the tracker treats it
The certificate is a one-time filing at appearance, not a per-filing disclosure of AI use, so the entry records a verification duty rather than a disclosure duty. The requirement is binding in cases before Judge Divine in either district.
Primary source
Judge Joshua M. Divine, Judge’s Requirements (Revised June 2026), Section XVIII