Missouri Court of Appeals for the Eastern District in St. Louis
ST. LOUIS — The Missouri Court of Appeals for the Eastern District has dismissed an appeal filed by a woman in a St. Louis County property dispute and ordered her to pay $10,000 in damages to another woman after finding the appeal frivolous and citing significant procedural deficiencies, including the use of fictitious legal cases generated by artificial intelligence.
In a decision filed June 2, a three-judge panel upheld a trial court ruling that vacated a default judgment Terrina Boatner had previously obtained in an action seeking to quiet title to a property on Capitol Drive in St. Louis County.
The appellate court concluded that Boatner’s appeal failed to comply with multiple Missouri Supreme Court rules governing notices of appeal, appellate records and briefing requirements.
The court further found that the appeal lacked merit and warranted sanctions under Rule 84.19.
The dispute originated when Boatner, acting without an attorney, filed a petition to quiet title against Tina Hickerson on March 10, 2025.
After attempts at personal service were unsuccessful, Boatner obtained an order allowing service by publication.
On July 14, 2025, the trial court entered a default judgment in Boatner’s favor.
The judgment invalidated a purported 2012 transfer of the property, ordered Hickerson’s name removed from the title and declared Boatner the rightful owner. A writ of possession was subsequently issued for Hickerson’s eviction from the property.
After learning of the judgment, Hickerson retained counsel and sought to stay enforcement of the writ and set aside the default judgment.
Hickerson later filed an amended motion to set aside the judgment under Rule 74.05 and a motion for relief from judgment under Rule 74.06(b), supported by a sworn affidavit and property records from the St. Louis County Recorder of Deeds and Assessor’s Office.
Following a hearing on Oct. 7, the trial court granted Hickerson’s motion, vacated the July 14 judgment and dismissed Boatner’s case with prejudice. The court also found Boatner lacked standing to bring the underlying action.
Boatner appealed, but the appellate court found numerous defects in her filings.
The court determined her notice of appeal failed to identify the final judgment being challenged, a requirement under Missouri appellate rules.
Instead, the notice referenced an order denying separate motions filed by Boatner rather than the Oct. 7 judgment that resolved the case.
The court also found the record on appeal incomplete.
Judges noted Boatner failed to provide all documents required for review and did not obtain or file a transcript of the Oct. 7 hearing despite being warned that failure to do so could result in dismissal.
In addition, the court concluded Boatner’s appellate brief failed to substantially comply with Rule 84.04, which governs the contents and format of appellate briefs.
According to the opinion, the brief contained deficiencies in its appendix, table of contents, statement of facts, points relied on and legal arguments. The court stated these shortcomings prevented meaningful appellate review.
Of particular concern to the court was Boatner’s citation of several cases that did not exist.
During oral argument, Boatner acknowledged using artificial intelligence to draft portions of her brief. The court reviewed the authorities cited and found that only two of the six referenced cases were real, while the remaining cases were fictitious.
The opinion stated that citing nonexistent cases constituted making false statements to the court and described the practice as an abuse of the judicial system.
The judges noted that parties, including those representing themselves, have a duty to verify the authorities they cite and remain responsible for the accuracy of their filings regardless of whether artificial intelligence tools were used.
The court referenced its earlier decision in Kruse v. Karlen, which warned litigants about the consequences of filing briefs containing fictitious citations generated by artificial intelligence.
The judges said Boatner’s conduct warranted dismissal and sanctions.
In assessing damages, the court found the appeal presented no justiciable question and was readily recognizable as lacking merit.
The judges noted Hickerson was required to expend additional resources defending the appeal, including filing a motion to dismiss, correcting deficiencies in the appellate record, responding to Boatner’s claims and attending oral argument.
As a result, the court awarded Hickerson $10,000 in damages under Rule 84.19. The opinion states the award is to compensate Hickerson for attorney fees incurred in defending the appeal and to promote the integrity of the judicial process.
Presiding Judge Michael S. Wright authored the opinion, with Judges Philip M. Hess and Virginia W. Lay concurring.
The court dismissed the appeal and entered judgment against Boatner in the amount of $10,000 in favor of Hickerson.
Missouri Court of Appeals for the Eastern District case number: ED113978
