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AI failures · Fabricated content

Wadsworth v. Walmart Inc. — Morgan & Morgan Attorneys Fined for AI-Fabricated Citations

Verified Checked against its sources on 2 sources quoted

Where it happened
Wyoming, United States
Organization
Morgan & Morgan P.A.
Date
2025-02-24 (sanctions order)
Function
Legal
Where it happened
Legal research; brief drafting
System
MX2.law (Morgan & Morgan's in-house AI platform)
Technology
Generative AI
Type of failure
Fabricated content
Caught by
The opposing party, A court

Summary

In a product-liability suit against Walmart and Jetson Electric Bikes in the U.S. District Court for the District of Wyoming, plaintiffs' lawyers from Morgan & Morgan filed motions in limine on January 22, 2025, that cited nine cases, eight of which did not exist. The drafting lawyer had used the firm's in-house AI platform to add case law. The defendants' response pointed to possible AI use, the court issued an order to show cause, and the lawyers admitted the cases were AI hallucinations and withdrew the motions. On February 24, 2025, Judge Kelly H. Rankin revoked the drafting lawyer's pro hac vice admission and fined him $3,000, and fined the two lawyers who signed the motions without checking them $1,000 each. The firm itself was not sanctioned.

Consequence

  • Drafting lawyer's pro hac vice admission revoked and $3,000 fine; the two signing lawyers fined $1,000 each; the firm was not sanctioned

Who caught it The opposing party, A courtFound outside the organization

Analysis

What could have been done

Checking AI output against its sources

Every factual element of AI output (citations, figures, quotations) is checked against its source before reliance.

The motions in limine cited nine cases, eight of which did not exist; the drafting lawyer had used the firm's in-house AI platform to add the case law.

A review that can actually catch the error

The reviewer has the time, information and expertise to catch the error, not only to sign off.

The two lawyers who signed the motions did so without checking them, so their signatures added no check of the citations.

What would likely have prevented it

  • Make a signature on a filing mean that the signer, or a named delegate, has checked each cited authority against an authoritative source, and keep a record of that check.
  • Where the organization supplies its own AI drafting tool, build into the drafting workflow a required step in which every authority the tool added is verified before the draft goes to the signers.

What would likely have caught it earlier

  • Before an AI-assisted filing goes out, have someone other than the drafter confirm that each cited case exists; with eight of nine citations non-existent, even a partial check would likely have exposed the problem.

Related reading Review Is a Control Only When It Can Catch the ErrorTreat AI Output Like an Unsupported Journal EntryMost Documented AI Failures Were Found by Someone Else

Key dates

  1. February 24, 2025Event
  2. October 16, 2026Checked against sources
  3. October 18, 2026Checked against sources
  4. October 21, 2026Checked against sources

Developments are added when the record is reviewed. Next review: October 16, 2027.

Evidence

Each passage is quoted from its source. The quoted passages are re-checked against the live pages every month.

  1. Ayala had his pro hac vice status in the case revoked and he was fined $3,000. Morgan and Goody were each fined $1,000, but Morgan & Morgan wasn't sanctioned

    Supports: Sanctions on each lawyer; firm not sanctioned

    Morgan & Morgan Lawyers Fined for 'Hallucinated' AI Citations Bloomberg Law Reporting or analysis

  2. Plaintiffs' attorneys, Mr. Rudwin Ayala, Mr. T. Michael Morgan, and Ms. Taly Goody (collectively "Respondents"), filed Motions in Limine that cited nine cases, but eight did not exist.

    Supports: Who filed; nine cases cited, eight non-existent; order dated 24 Feb 2025; AI platform and detection described in the order

    Order on Sanctions and Other Disciplinary Action, Wadsworth v. Walmart Inc., No. 2:23-cv-00118-KHR (D. Wyo. Feb. 24, 2025), ECF No. 181 U.S. District Court for the District of Wyoming (via CourtListener RECAP) Primary source

Suggested citation. Eminence Scan, “Wadsworth v. Walmart Inc. — Morgan & Morgan Attorneys Fined for AI-Fabricated Citations”, Eminence Growth Solutions, last verified October 16, 2026, https://eminencegrowthsolutions.com/tools/eminence-scan/record/fail-002/.

Using our research: you may read and quote Eminence Scan with credit to “Eminence Scan, Eminence Growth Solutions” and a link; all other rights reserved. Terms: Using our research.

Spotted an error, or a development we have missed? Report a correction. How we check records: research methodology.