A $1,000 fine in Wyoming just cost a Florida lawyer his shot at appearing in a high-profile Massachusetts case against Harvard. If you were previously sanctioned for using hallucinated citations because of AI or are still not verifying your citations, this case should be of interest to you.
The Background
In February 2025, Judge Kelly Rankin of the U.S. District Court for the District of Wyoming sanctioned T. Michael Morgan, a Morgan & Morgan partner, for filing motions in limine that cited nine cases, eight of which did not exist. The citations that did not exist had been hallucinated by the firm’s in-house AI platform, MX2.law. Morgan admitted that he never read the motions before they went out under his signature. The court found a violation of Rule 11(b) and imposed a $1,000 fine. See Wadsworth v. Walmart Inc. Morgan paid the fine. It is unlikely that Morgan thought that the hallucinated citations would cause him problems in the future. Yet, they did.
On May 18, 2026, Justice Kenneth Salinger of the Massachusetts Superior Court denied Morgan’s motion to appear pro hac vice in a consolidated set of actions against Harvard. The order rested on two independent grounds: the Wyoming sanctions and Morgan’s handling of the pro hac vice motion itself. See Wilder v. President & Fellows of Harvard College. When it comes to pro hac vice admission, the court has broad discretion. In this case, Justice Salinger looked at Morgan’s Wyoming conduct as a serious ethical transgression. Justice Salinger specifically noted that senior attorneys carry the same duty as their associates to make sure filings are accurate.
This has been something I have addressed frequently in my posts on AI hallucinations. Judges expect senior attorneys to make certain that any document they sign or have supervisory authority over has been reviewed by that attorney and is correct. While Morgan signed the filing in the Wyoming case, it is not necessary for a supervisory attorney to sign a filing to be found responsible for failing to properly supervise their employees.
While Morgan disclosed the Wyoming sanctions in his motion, as he was required to do, he failed to address what measures Morgan & Morgan took to prevent similar problems in the future. For example, Morgan provided no information about new verification procedures, firm-wide policies, training, or any other corrective step. Justice Salinger called the omission “surprising. And troubling.”
Morgan’s handling of the pro hac vice motion itself gave the court a second, independent ground for denial. He filed the motion under his own name, in violation of SJC Rule 3:15, which requires that a member of the Massachusetts bar file it. Because Morgan is not admitted in Massachusetts and had not been granted permission to appear, filing the motion himself meant he practiced law in Massachusetts without permission, in violation of G.L. c. 221, § 46A. Justice Salinger called this ‘not a minor technical violation,’ quoting the Supreme Judicial Court’s statement that permission to appear is ‘not merely important but is essential.’ He also paid a $100 fee instead of the $355 the rule requires. The court treated these missteps as confirmation that Morgan still was not reading documents, in this case Massachusetts rules, carefully.
If You Have Been Sanctioned for Hallucinations, Make Sure You Fix the Problem
The lesson here is straightforward. An attorney’s reputation is easily damaged. When a lawyer is publicly sanctioned, the sanction becomes a part of their professional record. Hallucination cases are followed closely by many, and even had the Justice not seen Morgan’s prior sanction, the obligation to report it brought it to the Justice’s attention. Morgan & Morgan did take steps. Judge Rankin’s order documents them: the firm trained its employees not to use MX2.law the way the associate had, and it added an acknowledgment requiring users to independently verify AI-generated information before relying on it. Rankin credited those measures and declined to sanction the firm, saying further sanction would be greater than necessary. The record existed. It seems that Morgan simply did not put it in front of the Massachusetts court.
My Suggestions
A few practical points. Read what you sign. The duty to verify is nondelegable, no matter which associate or AI tool generated the draft. If you are a supervising attorney, you should make sure that your firm’s workflows include a verification step for all citations, regardless of whether they are due to AI or traditional legal research. If you do get sanctioned, document your corrective steps. When the next court asks what has changed, have an answer ready. And when you move into a new jurisdiction, follow its rules to the letter. A sloppy motion in the new court confirms the very thing you are trying to overcome. It is the job of attorneys to be precise in their filings. Similarly, it is the job of supervisory attorneys to make certain that the work filed by those they supervise is correct.
Hallucinated citations follow the lawyer. It is rare to be denied pro hac vice admission, but here we are. The firm had modified its workflow. What it seems not to have fixed at the time of this opinion was the individual failure. The training and the verification prompt were aimed at the AI platform, and Morgan’s violation was signing a document he never read. A pop-up on a research tool does not fix that. Salinger’s complaint was precisely that Morgan made no showing he had changed his own practice of reviewing what he signs.
Obviously, it is better to never use hallucinated citations or facts in your court filings. But if you have been caught in the past, it is critical that you do everything in your power to avoid any mistakes in the future. In law, we don’t get three strikes before we are out. In this case, Morgan got just one.