Tips for Avoiding the Pitfalls of AI in Legal Practice: Missouri’s Evolving Rules on AI Disclosure

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Published:

March 24, 2026

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3 min read

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Best Practices for AI Use in Missouri Courts, Missouri AI Disclosure Rules for Attorneys

About the Author(s)

Alemayehu A. Ayanaw

Alemayehu (Ali) Ayanaw specializes in complex business litigation, with a focus on asbestos, talc, and mass toxic tort matters as well as premises, retailer, and product liabilities cases. He has a proven track record of effectively advocating for manufacturers, retailers, and premises owners in large-scale toxic tort litigation, securing favorable results via motion practice and settlement negotiations. He is experienced in preparing for and defending clients in trials concerning lawsuits alleging asbestos exposure, whether as manufacturers of products or owners of premises.

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Gabrielle A. Deimeke

Gabrielle A. Deimeke defends clients involved in motor vehicle accidents, premises liability claims, and trucking and transportation issues. She provides them with personalized legal support that aligns with their unique needs and helps them achieve their goals.

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The Takeaway

The best ways to avoid the risks associated with using an AI tool to prepare legal filings in Missouri courts include the following:

Verify the accuracy of AI-generated content.

Disclose the identity and use of any AI tool.

Know, understand, and follow local court rules on the use of AI.

Continue to exercise professional judgment over the content of documents filed with a court.

Missouri Case Highlights the Problems

The advancement of generative artificial intelligence (Gen AI) tools has revolutionized many industries, including the legal profession. However, the use of Gen AI in legal practice is not without significant risks. As discussed below, Kruse v. Karlen highlights the importance of accuracy, ethical responsibility, and compliance with procedural rules when using AI tools to prepare court documents.

In Kruse v. Karlen, the Missouri Court of Appeals dismissed an appeal and imposed sanctions after a pro se appellant submitted an appellate brief riddled with fictitious case citations and misrepresented legal authorities. 692 S.W.3d 43 (Mo. Ct. App. 2024). The appellant admitted to hiring an online consultant who used generative AI to draft the brief. The AI-generated content included fabricated case law and statutory references, which the appellant failed to verify.

Despite the appellant’s apology and claimed ignorance regarding the consultant’s use of AI, the court found the submission to be a flagrant violation of procedural rules and the duty of candor owed to the court. It emphasized that citing nonexistent case law or misrepresenting legal authorities constitutes a false statement to the court, even if the error originated from an AI tool. The court awarded the respondent $10,000 in damages for the appellant having filed a frivolous appeal. This case underscores the critical need for attorneys to verify the accuracy of AI-generated content before submitting it to the court.

Missouri Courts Respond with New Rules

In response to the growing use of generative AI in legal practice, several Missouri judicial circuits have enacted local rules requiring the disclosure of Gen AI use in court filings. These rules aim to ensure transparency, accountability, and adherence to ethical standards.

Filers must disclose whether they used AI in preparing court documents, identify the specific Gen AI tool used, and describe how it was utilized. (See Mo. 46^th Judicial Cir. R. 3.3; Mo. 17^th Judicial Cir. R. 3.3; Mo. 20^th Judicial Cir. R. 17; Mo. 7^th Judicial Cir. R. 3.3.1.)
Parties must certify that they’ve verified the accuracy of any AI-generated content, including legal citations and authorities. (See Mo. 46^th Judicial Cir. R. 3.3; Mo. 17^th Judicial Cir. R. 3.3; Mo. 20^th Judicial Cir. R. 17; Mo. 7^th Judicial Cir. R. 3.3.1.)
Courts may impose sanctions on parties who fail to disclose Gen AI use or certify the accuracy of Gen AI-generated content. For instance, the 20^th Judicial Circuit explicitly warns that noncompliance with its Gen AI disclosure rule may lead to sanctions. (See Mo. 20^th Judicial Cir. R. 17.)

Best Practices in Using AI

To mitigate the risks associated with using AI, legal professionals should adopt the following best practices:

Verify AI-generated content.
Always review and confirm the accuracy of legal citations, authorities, and factual assertions generated by Gen AI tools. Do not rely solely on AI outputs without independent verification.
Disclose AI Use.
Comply with local rules requiring disclosure of Gen AI use in court filings. Clearly identify the Gen AI tool used and the extent of its involvement in the preparation of the document.
Exercise Professional Judgment.
Remember that Gen AI is a tool, not a substitute for professional judgment. Attorneys remain responsible for the content of their filings and must ensure that their arguments are grounded in existing law or a reasonable extension of it.

Conclusion

The case of Kruse v. Karlen serves as a stark reminder of the potential pitfalls of using generative AI in legal practice without independent verification. While Gen AI tools can enhance efficiency and productivity, they also pose significant risks if used irresponsibly. Missouri’s local rules on Gen AI disclosure reflect a growing recognition of these risks and a commitment to maintaining the integrity of the judicial process. By adhering to these rules and exercising due diligence, legal professionals can harness the benefits of Gen AI while upholding their ethical and professional responsibilities.