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Reason
Reason
Eugene Volokh

14th Court Case I've Seen in Which AI-Hallucinated Citations Appeared

From Kruse v. Karlen, decided yesterday by the Missouri Court of Appeals, in an opinion by Judge Kurt Odenwald, joined by Judges Michael E. Gardner and Renée D. Hardin-Tammons (for more on the earlier 13 cases, see these posts):

Jonathan R. Karlen ("Appellant") appeals from the trial court's grant of final summary judgment to Molly Kruse ("Respondent"). Due to numerous fatal briefing deficiencies under the Rules of Appellate Procedure that prevent us from engaging in meaningful review, including the submission of fictitious cases generated by artificial intelligence ("A.I."), we dismiss the appeal. Given the frivolousness of the appeal, we also award damages to Respondent pursuant to Rule 84.19.

The pro se appellant erred in many ways, but the court stressed the hallucinations:

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