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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
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Wadsworth v. Walmart (Morgan & Morgan)
D. Wyoming · Feb 24, 2025
WY / federalEditorial impact: mediumfake citationstorttrial
Direct answer
What happened in this matter?
Fabricated: Case Law | One of eight non-existent case citations in Plaintiffs' January 22, 2025 Motions in Limine; the Court confirmed it did not exist and deemed reliance on a fake opinion a Rule 11(b)(2) violation. Outcome: $3k Fine + Pro Hac Vice Revoked (Drafter); $1k Fine each (Signers); Remedial actions noted..
- Why the court cared
- The court acknowledged the attorneys' remedial steps and honesty but emphasized the non-delegable duty under Rule 11 to make a reasonable inquiry into the law before signing any filing. The court stressed that while AI can be a tool, attorneys remain responsible for verifying its output. The judge noted this was the "latest reminder to not blindly rely on AI platforms' citations"
- Why it matters now
- Internal firm AI platforms do not shield signers; every attorney on the signature block owes an independent Rule 11 inquiry.
Why this matter is tracked
Fabricated: Case Law | One of eight non-existent case citations in Plaintiffs' January 22, 2025 Motions in Limine; the Court confirmed it did not exist and deemed reliance on a fake opinion a Rule 11(b)(2) violation. Outcome: $3k Fine + Pro Hac Vice Revoked (Drafter); $1k Fine each (Signers); Remedial actions noted..
AI Use
Counsel from Morgan & Morgan used the firm's internal AI platform (MX2.law, reportedly using ChatGPT) to add case law support to draft motions in limine in a product liability case concerning a hoverboard fire. This was reportedly his first time using AI for this purpose.
Hallucination Details
Eight out of nine case citations in the filed motions were non-existent or led to differently named cases. Another cited case number was real but belonged to a different case with a different judge. The legal standard description was also deemed "peculiar".
Ruling/Sanction
After defense counsel raised issues, the Judge issued an order to show cause. The plaintiffs' attorneys admitted the error, withdrew the motions, apologized, paid opposing counsel's fees related to the motions, and reported implementing new internal firm policies and training on AI use. Judge Rankin found Rule 11 violations. Sanctions imposed were: $3,000 fine on the drafter and revocation of his pro hac vice admission; $1,000 fine each on the signing attorneys for failing their duty of reasonable inquiry before signing.
Key Judicial Reasoning
The court acknowledged the attorneys' remedial steps and honesty but emphasized the non-delegable duty under Rule 11 to make a reasonable inquiry into the law before signing any filing. The court stressed that while AI can be a tool, attorneys remain responsible for verifying its output. The judge noted this was the "latest reminder to not blindly rely on AI platforms' citations".
Operational lesson
Internal firm AI platforms do not shield signers; every attorney on the signature block owes an independent Rule 11 inquiry.
Record details
WyomingSingle-state evidence scope
CourtD. Wyoming
Jurisdictionfederal
Circuit10th Circuit
DateFeb 24, 2025
IN
AI toolInternal tool (ChatGPT)
Party typeLawyer
Outcome$3k Fine + Pro Hac Vice Revoked (Drafter); $1k Fine each (Signers); Remedial actions noted.
Known amount$5,000
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
Internal tool (ChatGPT) is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
$3k Fine + Pro Hac Vice Revoked (Drafter); $1k Fine each (Signers); Remedial actions noted.
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
8 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | One of eight non-existent case citations in Plaintiffs' January 22, 2025 Motions in Limine; the Court confirmed it did not exist and deemed reliance on a fake opinion a Rule 11(b)(2) violation.
- Fabricated: Case Law | One of eight non-existent case citations in Plaintiffs' January 22, 2025 Motions in Limine; the Court confirmed it did not exist and deemed reliance on a fake opinion a Rule 11(b)(2) violation.
- Fabricated: Case Law | One of eight non-existent case citations in Plaintiffs' January 22, 2025 Motions in Limine; the Court confirmed it did not exist and deemed reliance on a fake opinion a Rule 11(b)(2) violation.
- Fabricated: Case Law | One of eight non-existent case citations in Plaintiffs' January 22, 2025 Motions in Limine; the Court confirmed it did not exist and deemed reliance on a fake opinion a Rule 11(b)(2) violation.
- Fabricated: Case Law | One of eight non-existent case citations in Plaintiffs' January 22, 2025 Motions in Limine; the Court confirmed it did not exist and deemed reliance on a fake opinion a Rule 11(b)(2) violation.
- Fabricated: Case Law | One of eight non-existent case citations in Plaintiffs' January 22, 2025 Motions in Limine; the Court confirmed it did not exist and deemed reliance on a fake opinion a Rule 11(b)(2) violation.
- Fabricated: Case Law | One of eight non-existent case citations in Plaintiffs' January 22, 2025 Motions in Limine; the Court confirmed it did not exist and deemed reliance on a fake opinion a Rule 11(b)(2) violation.
- Fabricated: Case Law | One of eight non-existent case citations in Plaintiffs' January 22, 2025 Motions in Limine; the Court confirmed it did not exist and deemed reliance on a fake opinion a Rule 11(b)(2) violation.
Questions this record answers
- What happened in Wadsworth v. Walmart (Morgan & Morgan)?
- Fabricated: Case Law | One of eight non-existent case citations in Plaintiffs' January 22, 2025 Motions in Limine; the Court confirmed it did not exist and deemed reliance on a fake opinion a Rule 11(b)(2) violation. Outcome: $3k Fine + Pro Hac Vice Revoked (Drafter); $1k Fine each (Signers); Remedial actions noted..
- Why does Wadsworth v. Walmart (Morgan & Morgan) matter for legal AI risk?
- Internal firm AI platforms do not shield signers; every attorney on the signature block owes an independent Rule 11 inquiry.
- What does the public record establish about Wadsworth v. Walmart (Morgan & Morgan)?
- The record summarizes the outcome described in the linked public source. The recorded link is a secondary or other public source and should be checked against the docket where available. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Wadsworth v. Walmart (Morgan & Morgan) summary?
- The recorded source is CourtListener / RECAP. It is classified as docket or legal-document mirror; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.