Morgan & Morgan lawyers sanctioned for AI-generated fake citations in Wyoming case
Morgan & Morgan attorneys were sanctioned in the District of Wyoming for filing a motion containing eight fabricated case citations generated by an internal AI platform. The court fined three attorneys a total of $5,000 and removed Rudwin Ayala from the case.
The cases cited by the court had been 'hallucinated' by an internal AI platform and were not legitimate.
Key facts
- What
- Morgan & Morgan attorneys were sanctioned in the District of Wyoming for filing a motion containing eight fabricated case citations generated by an internal AI platform.
- Incident date
- Jan 22, 2025
- Who
- Morgan & Morgan
- Failure mode
- Hallucination
- AI surface
- Chatbot
- Severity
- Medium
What happened
In Wadsworth v. Walmart, Morgan & Morgan attorneys filed a motion on January 22, 2025 containing eight fabricated case citations. The lawyers later admitted these citations were hallucinated by an internal AI platform. The court imposed sanctions totaling $5,000 and revoked Rudwin Ayala's pro hac vice status, removing him from the case.
What broke inside the model
- 01 · TriggerA user asks for a fact, a citation, or a figure.
- 02 · Model stepThe model writes a fluent, confident answer.
- 03 · Control gapNothing ties the claim back to a real source.
- 04 · FailureA fabricated fact ships as if it were verified.
- 05 · ConsequenceThe false claim reaches a customer, a court, or the public.
Confidence holds, and even spikes, as the claim detaches from any source.
The attorneys did not verify the authenticity of the generated citations before submitting the motion to the court, allowing hallucinated authorities to be presented as genuine.
What it cost
Sources
- PressNo. 42 law firm by headcount could face sanctions over fake case citations generated by ChatGPTabajournal.com
- PressJudge Fines Three Lawyers for Citing AI-Generated Fake Casesnews.justia.com
- Court FilingWADSWORTH v. WALMART INC LLC (2025)caselaw.findlaw.com
Cite this entry
https://failureindex.ai/failures/morgan-morgan-lawyers-sanctioned-generated-fakeAI Failure Index. "Morgan & Morgan lawyers sanctioned for AI-generated fake citations in Wyoming case" (FI-0266). Realm Labs. https://failureindex.ai/failures/morgan-morgan-lawyers-sanctioned-generated-fake (indexed Jun 5, 2026).Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0266. Full dataset at /data.
Note from Realm Labs, the Index steward
How Realm would have caught this
- Prism
- OmniGuard
- AI Detection & Response (AIDR)
A runtime layer that watches the model's internal state can flag the moment a model commits to a claim it has no support for, and hold or reroute the response before it reaches a user. Realm reads those signals in real time rather than grading the transcript after the fact.