Wadsworth v. Walmart (Morgan & Morgan)
D. Wyoming · Feb 24, 2025
- Jurisdiction
- federal
- Court
- D. Wyoming
- Record ID
- wadsworth-v-walmart-morgan-morgan-2025-02-24
- Observed outcome
- The court revoked the drafter's pro hac vice admission and imposed a $3,000 fine on the drafter, and $1,000 fines on each of the two signing attorneys.
- Known monetary consequence
- $5,000
Why this matter warrants attention
The court sanctioned three attorneys for Rule 11(b)(2) violations after they submitted motions containing fabricated AI-generated case law. The court revoked the drafter's pro hac vice admission and imposed a $3,000 fine on the drafter, plus $1,000 fines on each of the two signing attorneys for failing to perform a reasonable inquiry into the filings.
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"
Internal firm AI platforms do not shield signers; every attorney on the signature block owes an independent Rule 11 inquiry.
Failure modes and consequences
- Fake Citations
- Tort
- Trial
- Monetary
- Professional
- AI attribution
- Admitted
- Recorded tool
- MX2.law
- Known monetary consequence
- $5,000
- Procedural posture
- Following a show cause order regarding fabricated citations in motions in limine, the court issued a written order imposing sanctions under Rule 11 and its inherent authority.
CourtListener / RECAP
Docket or legal-document mirror. The recorded link is hosted by a legal document repository or mirror.
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What this record does—and does not—establish
The drafter used the firm's internal database, MX2.law, to generate the motions.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all AI-generated legal research before inclusion in court filings.
- Ensure every attorney on a signature block independently reviews the legal authority cited in the document.
- Avoid 'rubber stamping' filings prepared by other counsel, including those admitted pro hac vice.
- Establish firm-wide policies requiring the use of verified, traditional legal research databases for final citation checks.