ST. CHARLES COUNTY, Mo. – An O’Fallon man apparently used artificial intelligence to generate more than 20 fake court case citations in legal briefs. A state appeals court ordered him to pay $10,000 in fines on Tuesday.
According to court documents, a judge from the Eastern District of the Missouri Court of Appeals ordered Jonathan R. Karlen to pay $10,000 to Molly Kruse in damages.
Court documents state that during recent legal briefs, Karlen cited only two legal precedents out of 24 citations.
“We regret that Appellant has given us our first opportunity to consider the impact of fictitious cases being submitted to our Court, an issue which has gained national attention in the rising availability of generative A.I.,” said Missouri appellate court documents from Tuesday.
The court documents also assert that citing nonexistent case laws is a violation of making a false statement in court.
Per court documents, after submitting briefs with fake citations, Karlen said that he hired an online “consultant” purporting to be an attorney licensed in California to prepare an appellate brief. He claimed he did not know that the “consultant” would use “artificial intelligence hallucinations” in preparing briefs.
The New York Times reports of a similar legal battle last year in which a lawyer used ChatGPT to prepare for court proceedings and cited fake cases, eventually ordered to pay thousands of dollars in sanctions.