State of Missouri ex rel. Steven Schnell v. Hon. Rebecca Richardson
The case
State ex rel. Schnell v. Richardson, No. ED114731, Mo. Ct. App., Eastern District, Writ Division Four, order filed September 8, 2026. Primary order: https://www.damiencharlotin.com/documents/3051/State_of_Missouri_v._Richardson_USA_8_September_2026.pdf
What happened
Relator's counsel Jenna Rohr Conley filed a writ-of-mandamus petition (seeking transfer of a termination-of-parental-rights/adoption matter to St. Charles County) citing two cases supposedly holding that all cases involving one family must be heard by a single judge. The citations were fictitious, they did not correspond to real cases, and the cases found at those names did not support the propositions. The court acted on her representations and ordered respondent to file suggestions in opposition before discovering the problem. In response to a show-cause order, Conley admitted she had used generative AI to research authorities but failed to verify the citations, and could not identify any real case supporting her position.
The rule and the sanction
Violation of Missouri Supreme Court Rule 55.03, by signing, an attorney certifies the filing is "warranted by existing law" and formed after "reasonable inquiry," an objective standard. The court held that citing nonexistent law fails both prongs, and that "at this point in time, generative AI's tendency to fabricate caselaw and citations is well documented," making unverified AI research objectively unreasonable (citing Kruse v. Karlen, Mata v. Avianca, and Mo. Informal Op. 2024-11). Sanction: $1,750 under Rule 55.03(c), payable to the petitioners in the underlying action (K.N.O. and J.W.O.) for reasonable attorney's fees incurred responding to the writ. The writ petition was denied. The order expressly notes it is not sanctioning Conley for using generative AI but for filing pleadings citing nonexistent cases; it declined to decide professional-discipline questions, reserving those to the Supreme Court of Missouri.
How it could have been avoided
Pull and read every cited case in the actual reporter before filing, a same-name case at the wrong citation does not support your proposition. Run every authority through Shepard's/KeyCite to confirm existence, court, and holding. The court's "well documented" language means Missouri lawyers can no longer plead ignorance of AI fabrication risk.