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 focused on the Wyoming sanctions. 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 also made several errors when he filed his request for pro hac vice admission, which certainly didn’t help his case. 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 the pro hac vice motion. Filing the motion on his own meant Morgan was practicing law in Massachusetts “without permission.” He also paid a $100 fee instead of the $355 fee that 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. While I assume Morgan & Morgan has taken steps to prevent future hallucination problems, Morgan himself should have explained what those steps were. Further, he should have been extremely careful to make certain any filings were 100% correct before he submitted them.
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. Not only does Morgan & Morgan have to deal with the embarrassment of this situation again, but it now looks as if it has not modified its workflow, regardless of whether it has made such modifications.
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.