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Incident Tracker / United States (federal)

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

·US District Court, District of Wyoming·US-FEDSanctions

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.

Court
US District Court, District of Wyoming
Date
2025-02-24
Who used the AI
Not recorded
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.
Outcome
Sanctions
Penalty
US$5,000
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
Not separately recorded

What was fabricated or misused

  • Wyoming v. U.S. Department of Energy, 2006 WL 3801910 (D. Wyo. 2006) — one of the eight non-existent cases cited in ECF 141
  • Holland v. Keller, 2018 WL 2446162 (D. Wyo. 2018) — one of the eight non-existent cases cited in ECF 141
  • United States v. Hargrove, 2019 WL 2516279 (D. Wyo. 2019) — one of the eight non-existent cases cited in ECF 141
  • Meyer v. City of Cheyenne, 2017 WL 3461055 (D. Wyo. 2017) — one of the eight non-existent cases cited in ECF 141
  • Benson v. State of Wyoming, 2010 WL 4683851 (D. Wyo. 2010) — one of the eight non-existent cases cited in ECF 141
  • Smith v. United States, 2011 WL 2160468 (D. Wyo. 2011) — one of the eight non-existent cases cited in ECF 141
  • Woods v. BNSF Railway Co., 2016 WL 165971 (D. Wyo. 2016) — one of the eight non-existent cases cited in ECF 141
  • Fitzgerald v. City of New York, 2018 WL 3037217 (S.D.N.Y. 2018) — one of the eight non-existent cases cited in ECF 141

What the court said

“On January 22, 2025, 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.”
US District Court, District of Wyoming, p. 3
“These search inquiries apparently generated the fake cases. Without verifying their accuracy, Mr. Ayala included the fake cases in the Motions in Limine.”
US District Court, District of Wyoming, p. 5
“Because there is no dispute that Respondents cited fake cases in a signed motion, Respondents’ conduct violates Rule 11(b)(2).”
US District Court, District of Wyoming, p. 7
“The key takeaway for attorneys is simple: make a reasonable inquiry into the law before signing (or giving another permission to sign) a document, as required by Rule 11.”
US District Court, District of Wyoming, p. 10

Timeline

  1. Plaintiffs’ attorneys filed motions in limine with nine cited cases, eight non-existent.
  2. Court issued an order to show cause on sanctions or other discipline.
  3. Plaintiffs withdrew the motions in limine.
  4. Attorneys admitted the cases were not real and were hallucinated by an AI platform.
  5. Attorneys filed responses to the order to show cause.
  6. Court sanctioned Ayala $3,000 and Morgan and Goody $1,000 each.

Why this case matters

Wadsworth is not a ChatGPT record like Mata v Avianca or Park v Kim. The citations came from Morgan & Morgan’s internal MX2.law tool, so the case tests whether private firm software changes Rule 11 duties. Judge Rankin said it did not. The sanctions also reached lawyers who did not draft the motions but signed them or allowed signatures to be used, making the record a warning about supervisory and local-counsel review in AI-assisted filings.

Practice note

Treat an in-house AI platform like any outside source: every case must be opened in a legal database, read, and checked for the proposition cited. Supervising and local counsel should not allow e-signatures on motions they have not reviewed. Missing dates, no pin cites, or unfamiliar district cases are red flags to stop filing.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Wadsworth v. Walmart, Inc., 348 F.R.D. 489 (D. Wyo. 2025)”, safelegalai.com/tracker/wadsworth-v-walmart (accessed 2026-09-16). Data: CC BY 4.0.

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