Glenn Wilder and Others v. President & Fellows of Harvard College and Others

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

11(b) because he signed motions in limine without reading them and, as a result, permitted the filing of motions citing eight non-existent cases that had been hallucinated by Morgan & Morgan’s in-house Artificial Intelligence (“AI”) platform. See Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. Feb. 24, 2025). The Court will exercise its discretion to deny Attorney Morgan’s motion for permission to appear in this case pro hac vice. The Court is troubled by Morgan’s demonstrated failure in the Wyoming case to live up to the ethical - 2 - standards required of trial lawyers. Its concern is heightened by Morgan’s decision to practice law in Massachusetts without permission, by filing his motion in violation of the statute (G.L. c. 221, § 46A) and the Massachusetts Supreme Judicial Court rule (SJC Rule 3:15) that govern pro hac vice motions. In light of Morgan’s recent misconduct in Federal court, and his disregard of Massachusettslawandproceduralrules inthiscase,theCourtisnotpersuaded that Morgan should be granted permission to appear before the Massachusetts Superior Court. 1. Legal Background. ... In February 2025, a Federal District Judge sanctioned Attorney Morgan for submitting motions citing to cases that had been hallucinated by an AI - 3 - platform. Judge Kelly H. Rankin set forth his findings and conclusions about Morgan’s ethical lapses in an “Order on Sanctions and Other Disciplinary Action.” See Wadsworth, 348 F.R.D. 489. Judge Rankin found that in January 2025 Attorney Morgan, as well as his associate at Morgan & Morgan and his local counsel, violated Fed. R. Civ. P. 11(b) by filing motions in limine that cited nine cases, eight of which did not exist.

Authorities cited in the passage: See Wadsworth v. Walmart Inc., 348 F · Rule 3 · Fed. R. Civ. P. 11(b)