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AI rules by state · MO

AI Rules for Lawyers in Missouri 2026

By Sabih Siddiqi, founder of Irys and former BigLaw litigatorVerified as of June 2026
AI disclosure required?Case-by-case
Governing guidanceInformal Opinion 2024-11
Competence ruleRule 4-1.1
AI / technology CLENo tech or AI requirement

Quick answer

Missouri does not require lawyers to disclose AI use as a blanket rule. The state's Informal Opinion 2024-11 applies the existing duties to AI and requires verification of AI output. A Missouri appellate court has already fined a litigant $10,000 for filing fabricated AI citations.

Ethics guidance

Missouri Informal Opinion 2024-11

April 2024

Missouri's reference point is Informal Opinion 2024-11, issued by the Office of Legal Ethics Counsel and the Advisory Committee of the Supreme Court of Missouri in April 2024.

The opinion is non-binding initial guidance. It applies the duties of competence, confidentiality, candor to the tribunal, and supervision to AI, and requires the lawyer to verify all AI output before relying on it.

Source: Missouri, Informal Opinion 2024-11

Disclosure rules

Are Missouri lawyers required to disclose AI use?

Missouri imposes no blanket duty to disclose AI use. The opinion focuses on verification, confidentiality, and candor, and directs lawyers to comply with any court order about AI.

Counsel should review the assigned judge's standing order in each matter.

Source: Missouri, Informal Opinion 2024-11

Sanctions on record

AI hallucination sanctions in Missouri

Missouri courts have acted on fabricated AI citations. In Kruse v. Karlen (Missouri Court of Appeals, Eastern District, 2024), the court sanctioned a self-represented appellant $10,000 for a frivolous appeal in which 22 of 24 citations were AI-fabricated. The lesson applies to lawyers and litigants alike.

Source: Missouri appeals court fines litigant over fabricated AI cases (Missouri Independent)

Competence duty

The competence rule and AI (Rule 4-1.1)

The competence duty in Missouri is Rule of Professional Conduct 4-1.1. Informal Opinion 2024-11 reads it to require a working understanding of AI tools and verification of their output.

Source: Missouri, Informal Opinion 2024-11

CLE requirements

Continuing legal education in Missouri

Missouri requires 15 CLE hours per reporting period, including ethics credit. There is no AI or technology-specific requirement as of June 2026.

Source: Missouri CLE (ABA MCLE summary)

How to stay compliant

A practical checklist for Missouri lawyers

A Missouri appellate court has already imposed a $10,000 sanction for fabricated AI citations, so verification is the duty that matters most here.

Review the assigned judge's standing order and the court's local rules at the start of every matter. AI disclosure obligations generally sit at the court and judge level rather than in a single statewide rule.Verify every citation and quotation before filing, and read the underlying authority. Most AI sanctions have resulted from citations the lawyer never personally verified.Do not enter confidential client information into public AI tools without confirming how the tool handles data and, where there is material confidentiality risk, obtaining the client's informed consent.Inform the client when AI use materially affects the matter, and honor any client instruction that limits AI use.Bill only for time actually spent drafting prompts and reviewing output, not for time the tool saved.Keep any required technology or AI continuing-education credit current, and treat AI competence as part of your duty under the competence rule.When evaluating tools, look for citation grounding that ties output to verifiable authority, a vendor commitment not to train on client data, and audit trails. These reduce risk, but they do not replace the lawyer's own review.

Frequently asked

Missouri AI rules: common questions

Not as a blanket rule. Informal Opinion 2024-11 focuses on verifying AI output, protecting confidentiality, and candor, and directs lawyers to comply with any court order about AI.

Yes. In Kruse v. Karlen (Mo. Ct. App., E.D., 2024), the court fined a self-represented appellant $10,000 for a frivolous appeal where 22 of 24 citations were AI-fabricated. The same duty to verify applies to lawyers.

Missouri Rule of Professional Conduct 4-1.1. Informal Opinion 2024-11 reads it to require a working understanding of AI tools and verification of their output.

No. Missouri requires 15 CLE hours per reporting period, including ethics credit. There is no AI or technology-specific requirement.

Legal AI rules in nearby states

Practising across state lines? Compare Missouri’s rules with its neighbors.

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This page is general information, not legal advice. Rules change, and the obligations that apply to your matter depend on your court, your judge, and your facts. Verify the current rules with the Missouri state bar and the assigned court before you rely on anything here. Last verified June 2026.

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