Missouri

formal

Missouri Informal Opinion 2024-11 (April 25, 2024)

Summary

Missouri has Informal Opinion 2024-11 (April 25, 2024) from the Office of Legal Ethics Counsel and Advisory Committee of the Supreme Court of Missouri, two published Court of Appeals sanctions cases for AI-hallucinated citations (Kruse v. Karlen, February 2024, $10,000 sanction; Stevens v. BJC Health System, March 2025), and circuit-level AI disclosure rules in at least four judicial circuits. The Eastern District of Missouri has an AI accountability policy on its website. No statewide Missouri rule requires AI disclosure.

Applicable ABA Model Rules

Rule 4-1.1
Rule 4-1.5
Rule 4-1.6
Rule 4-3.3
Rule 4-3.4
Rule 4-5.1
Rule 4-5.3
Rule 4-5.4

Carrier Implications

Carriers take the position that if an attorney "blindly relied on AI hallucinations without validation," no professional service may have been rendered, potentially eliminating coverage. Firms should annually confirm LPL policy covers AI-assisted work product and that no AI-specific exclusion has been added by endorsement.

This summary is informational only. Verify the primary source before relying on this entry. Bar rules differ meaningfully by state. Consult a licensed attorney in your state.

Informal Opinion 2024-11 is non-binding initial guidance from the Office of Legal Ethics Counsel and Advisory Committee of the Supreme Court of Missouri, but the underlying Missouri Rules of Professional Conduct are binding. Attorneys must educate themselves on generative AI, assess platform terms of service and security before use, verify all AI-generated content, comply with court AI orders, maintain professional independence (cannot rely solely on AI), and supervise subordinates and nonlawyer staff using AI.

Missouri has active AI hallucination enforcement. In Kruse v. Karlen (Mo. Ct. App. E.D., February 13, 2024), 22 of 24 case citations in a brief were fictitious, the appeal was dismissed, and the court awarded $10,000 in sanctions under Rule 84.19. In Stevens v. BJC Health System (Mo. Ct. App. E.D., March 2025), the court characterized unverified AI citations as “an abuse of the adversary system” and warned of future sanctions. At least four judicial circuits (46th, 17th, 20th, 7th) have adopted local AI disclosure rules requiring identification of the AI tool and certification of citation accuracy. The Eastern District of Missouri has an AI accountability policy enforceable through FRCP 11(b).

Bottom line for a 5-50 attorney Missouri firm: Missouri has active AI hallucination enforcement, two Court of Appeals cases in 13 months. Four circuits have local AI disclosure rules. The informal opinion is explicit that written client consent is not required but platform security review and output verification are. Verify which circuits have disclosure rules before filing.

Last verified: April 23, 2026