Internet Law & Cyber-Security

Editors (4)

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Widener University Commonwealth Law School

Juliet Moringiello

Executive Editor, Internet Law & Cyber-Security
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Partridge Snow & Hahn LLP

John Ottaviani

Contributing Editor, Internet Law & Cyber-Security
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Aronberg Goldgehn

Alan S. Wernick

Contributing Editor, Internet Law & Cyber-Security
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MONTH-IN-BRIEF (Feb 2024)

Pro Se Appellant Sanctioned for Citations to Fictitious AI-Generated Cases

By Ke Liu (Kevin), Pilgrim Christakis LLP

On February 13, 2024, the Missouri Court of Appeals dismissed a pro se appellant’s appeal and entered sanctions against the appellant for, among other things, citing fictitious cases generated by artificial intelligence.

In the trial court, the appellee Molly Kruse filed suit seeking unpaid wages. The court granted summary judgment in Kruse’s favor, leading to appellant Jonathan Karlen’s pro se appeal. On appeal, Kruse moved to strike Karlen’s opening brief for failure to comply with various requirements of appellate procedure in Missouri. The appellate court noted numerous inadequacies with the brief, including the fact that it was not signed, there was no appendix, the statement of facts did not cite to the record, the table of contents and table of authorities were inaccurate, and the brief did not include a “points relied on” section summarizing the challenged ruling and the legal reasons for why the ruling should be reversed.

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