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Wadsworth v. Walmart (Morgan & Morgan)

Court
D. Wyoming
Jurisdiction
USA
Decided
2025-02-24
AI tool
Internal tool (ChatGPT)
Outcome
$3k Fine + Pro Hac Vice Revoked (Drafter); $1k Fine each (Signers); Remedial actions noted.
Monetary penalty
5000 USD

What was hallucinated

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.

Details

AI UseCounsel 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 DetailsEight 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/SanctionAfter 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 ReasoningThe 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".

Sanction teardown · D. Wyoming, USA · 2025-02-24

Wadsworth v. Walmart (Morgan & Morgan)

What happened

In D. Wyoming, USA, a filing relied on Internal tool (ChatGPT) to help draft legal argument. The court identified the following problems with the citations in that filing:

  • 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.

Which AI tool

Internal tool (ChatGPT). Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

$3k Fine + Pro Hac Vice Revoked (Drafter); $1k Fine each (Signers); Remedial actions noted. (monetary penalty: 5000 USD.)

Additional detail

AI UseCounsel 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 DetailsEight 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/SanctionAfter 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 ReasoningThe 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".

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://storage.courtlistener.com/recap/gov.uscourts.wyd.64014/gov.uscourts.wyd.64014.181.0_1.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://storage.courtlistener.com/recap/gov.uscourts.wyd.64014/gov.uscourts.wyd.64014.181.0_1.pdf

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