Kruse v. Karlen

Kruse v. Karlen, 692 S.W.3d 43 (Mo. Ct. App. 2024). Scope note: the sanctioned actor was a pro se appellant; the entry is included because the opinion is a leading AI-citation sanctions authority.

Karlen, who had counsel at trial but represented himself on appeal (with a hired online 'consultant'), filed briefs containing 22 fabricated citations and statutory errors traceable to unverified AI-generated research; he certified himself as self-represented.

$10,000 sanction for the filing misconduct.

Self-representation does not lower the verification duty: statutory citations need the same verification as case citations, check every cited statute section in the official code. A brief with 22 errors indicates no verification process at all; even spot-checking a sample would have revealed the systemic problem before filing.