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)

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 to the Missouri Court of Appeals, Eastern District (source). Karlen had been represented by counsel at trial but “proceeded pro se during the summary-judgment proceedings” and again on appeal (source). 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” (source).

What was built

This is not a technology deployment; it is an AI-governance outcome. The consultant’s brief was drafted with generative artificial intelligence, and the court found it cited authorities that do not exist (source). In the opinion’s words, “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 citations (source). Karlen “stated he did not know that the individual would use” what he described as “artificial intelligence hallucinations”; the opinion attributes the fabrications to AI but names no specific product (source). The Missouri Bar’s newsroom, reporting independently, described the brief’s citations as “artificial intelligence hallucinations” that either failed to support the cited propositions or were “entirely fictitious” (source).

The outcome

The number that gets quoted: 2 of 24 cited cases were genuine, and 22 were fabricated. The court held that “Only two out of the twenty-four case citations in Appellant’s Brief are genuine” (source). An independent narration puts it the same way: of Karlen’s 24 citations, “twenty-two (22) were fake” (source).

The sanction: $10,000 in damages under Rule 84.19. Because of “numerous fatal briefing deficiencies … including the submission of fictitious cases generated by artificial intelligence,” the court dismissed the appeal, and, “given the frivolousness of the appeal,” awarded damages “pursuant to Rule 84.19”: “Appellant is hereby ordered to pay Respondent damages in the amount of $10,000” (source). The court framed the conduct as a matter of candor: a brief “with bogus citations … cannot be countenanced and represents a flagrant violation of the duties of candor Appellant owes to this Court” (source). Two independent secondaries confirm the $10,000 frivolous-appeal award (source) (source). The court’s own opinion summary calls this the first decision in Missouri to focus on a litigant’s use of AI in preparing pleadings (source).

The $10,000 is distinct from the underlying wage litigation. The opinion notes the trial court separately “awarded Respondents in the amount of $91,908,” a figure unrelated to the AI issue; it is not to be conflated with the $10,000 appellate sanction (source).

How this was verified

The primary is the published Missouri Court of Appeals opinion in Kruse v. Karlen, No. ED111172, filed February 13, 2024 (Presiding Judge Kurt S. Odenwald; Judges Michael E. Gardner and Renée D. Hardin-Tammons concurring), a self-authenticating court document that needs no confirmation from any party (source). The official PDF from courts.mo.gov was byte-tied to a contemporaneous Wayback capture (timestamp 20240214212515), and every figure on this page was re-checked against that document live on 2026-08-16. The one figure that did not survive re-verification is a $311,313.70 underlying wage judgment carried by an earlier draft: that number appears nowhere in the appellate opinion, which instead records a separate trial-court award of $91,908, so the incorrect figure was removed rather than restated. The phrase “artificial intelligence hallucinations” is the appellant’s own characterization; it is corroborated by three mutually independent newsrooms rather than lifted cleanly from the machine-extracted opinion text, and is presented with that caveat.

Related case files

The same $10,000 sanction and the same “first in the jurisdiction” framing recur in Noland v. Land of the Free, California’s first published appellate opinion sanctioning AI-fabricated citations, which shows courts converging on a similar penalty for the same conduct. Where Kruse involved a non-lawyer relying on a fake “consultant,” Wadsworth v. Walmart shows the same fabrication reaching represented litigants: a $5,000 Rule 11 sanction against a large plaintiffs’ firm. And the Ninth Circuit’s suspension of counsel in Lnu v. Blanche marks the top of the ladder above a money sanction, where hallucinated citations cost licensed attorneys their ability to practice for six months.

Sources

Tier 1 = the court’s own opinion and summary (primary, self-authenticating). Tier 2 = independent legal press naming the parties. Each source was checked live on 2026-08-16.

1. Missouri Court of Appeals, Eastern District, “Kruse v. Karlen, No. ED111172” (opinion), filed 2024-02-13 (Tier 1, primary court document; byte-tied to Wayback capture 20240214212515). https://www.courts.mo.gov/file.jsp?id=205455
2. Missouri Court of Appeals, Eastern District, “Kruse v. Karlen” (opinion summary), 2024 (Tier 1, the court’s own summary; source of the “first decision in Missouri” framing). https://www.courts.mo.gov/file.jsp?id=205457
3. Missouri Bar, “Case summaries for Feb. 9 to Feb. 15, 2024,” 2024-02-16 (Tier 2, independent bar newsroom naming the case). https://news.mobar.org/cases-021624/
4. Ed Clinton, Jr., “Missouri Court Sanctions Litigant For Fake Citations,” Legal Ethics Lawyer, 2024-02-18 (Tier 2, independent legal-ethics practitioner blog quoting the opinion). https://legalethicslawyer.blog/2024/02/18/missouri-court-sanctions-litigant-for-fake-citations/
5. GOT Law, “Missouri Courts Tackle Artificial Intelligence” (Tier 2, independent law-firm commentary quoting the $10,000 award and the twenty-two-of-twenty-four count). https://gotlawstl.com/missouri-courts-tackle-artificial-intelligence/