# Kruse v. Karlen — Missouri appeals court fines a pro se litigant $10,000 after 22 of 24 cited cases turn out to be AI fabrications (Mo. App. E.D., Feb. 2024)

> A non-lawyer's AI-drafted appellate brief cited 24 cases; only two were real. The Missouri Court of Appeals dismissed the appeal as frivolous and ordered him to pay the opposing party $10,000 in damages.

- Verification status: verified
- Case type: deployment
- Provider: Generative AI (unnamed), used via an online 'consultant' to draft the brief
- Client: Missouri Court of Appeals, Eastern District — Kruse v. Karlen, No. ED111172, Courts / legal (AI-governance honest-negative) (named)
- Sector: legal / US / cross
- Verified on: 2026-08-01
- Canonical URL: https://theinternetninja.com/stories/kruse-v-karlen-pro-se-appellant-ai-fictitious-citations-22-of-24-fake-10000-frivolous-appeal-sanction-2024/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Outcomes

| Metric | Before | After |
| --- | --- | --- |
| $10,000 in Rule 84.19 damages ordered against the appellant for a frivolous appeal |  |  |
| 2 of 24 cited cases genuine — 22 fictitious, generated by AI |  |  |

## Verification method

Independent-origin state appellate opinion (ED111172), byte-tied to a contemporaneous Wayback capture; corroborated by three independent newsrooms.

## Full case file

**Verification status: IN CHECKING — not publish-ready, not `pending`, not verified.**

## The problem
Molly Kruse sued her former employer for unpaid wages and won summary judgment; the
company's owner, Jonathan R. Karlen — a non-lawyer — appealed. He had been represented by
counsel at trial but "proceeded pro se during the summary-judgment proceedings" and again on
appeal. To prepare his appellate brief, "he hired an online 'consultant' purporting to be an
attorney licensed in California," at a fee that "amounted to less than one percent of the cost
of retaining an attorney."

## What was built
The consultant's brief was drafted with generative AI. The Missouri Court of Appeals, Eastern
District, found that it cited authorities that do not exist: "Only two out of the twenty-four
case citations in Appellant's Brief are genuine," and the court "itemized each of the
twenty-two inaccurate case citations." Karlen "stated he did not know that the individual would
use 'artificial intelligence hallucinations'" — the opinion attributes the fabrications to AI
but names no specific product.

## The outcome
The court dismissed the appeal for "numerous fatal briefing deficiencies … including the
submission of fictitious cases generated by artificial intelligence," holding that a brief with
bogus citations "represents a flagrant violation of the duties of candor." Finding the appeal
frivolous, it ordered under Rule 84.19: "Appellant is hereby ordered to pay Respondent damages
towards appellate attorneys' fees in the amount of $10,000." (Distinct from — and not to be
conflated with — the underlying $311,313.70 trial-court wage judgment, which is unrelated to
the AI issue.)

## Path to green
The figures are court-ordered and self-authenticating; no client-confirmation call is required
for c1/c2. Before green, a human should confirm no motion for rehearing or transfer to the
Missouri Supreme Court vacated the $10,000 award (the official Case.net docket blocks this
host), and — if desired — obtain confirmation of whether the sum was paid. The specific AI
product is not named in the opinion and is asserted by no claim.