Incident Tracker

Wadsworth v. Walmart, Inc., 348 F.R.D. 489 (D. Wyo. 2025)

sanctions

In the US District Court for Wyoming, three Morgan & Morgan attorneys filed motions in limine citing nine cases, eight non-existent, generated by the firm's internal AI tool. Judge Kelly Rankin fined lead drafter Rudwin Ayala $3,000 and revoked his pro hac vice status; T. Michael Morgan and Taly Goody were fined $1,000 each under Rule 11.

Date of decision/order

2025-02-24

Court

US District Court, District of Wyoming

Jurisdiction

US-FEDERAL

AI tool

Morgan & Morgan internal AI tool (MX2.law)

Conduct

Three plaintiffs' attorneys filed motions in limine on 22 January 2025 citing nine cases, eight of which did not exist. The fabricated authorities were produced using the firm's internal AI research tool; the drafter did not verify them before filing, and defendants noted some mis-cited cases also appear on ChatGPT.

Consequence

USD 5,000