Hayes v. Miller
CA Missouri · Jun 16, 2026
- Jurisdiction
- state
- Court
- CA Missouri
- Record ID
- hayes-v-miller-2026-06-16
- Observed outcome
- The appellate court vacated the trial court's judgment in favor of Miller III on the unjust enrichment counterclaim.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court noted that the respondent's post-trial response brief contained several citations to nonexistent cases. However, the court did not impose sanctions or conduct a formal analysis of the citations, as the appeal was resolved on the procedural issue of the trial court's lack of authority to enter judgment for a non-party.
The court identified the citations as nonexistent in a footnote but did not rely on them for its decision, which was based on the trial court's lack of authority to enter judgment for a non-party.
This case illustrates a judicial encounter with AI-generated hallucinations in a legal brief. While the court noted the fabricated citations, it did not issue sanctions, highlighting that courts may prioritize procedural dispositive issues over addressing specific attorney misconduct in AI-assisted filings.
Failure modes and consequences
- Fake Citations
- Landlord Tenant
- Appellate
- None Adjudicated
- AI attribution
- Reported
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appeal from the Circuit Court of St. Louis County to the Missouri Court of Appeals, Eastern District.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification of all case law citations against official reporters before filing.
- Establish internal review protocols for briefs generated or assisted by AI tools to detect fabricated authorities.
- Monitor court dockets for judicial commentary on citation accuracy as an early indicator of potential professional scrutiny.