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Incident 960: Plaintiffs' Lawyers Admit AI Generated Erroneous Case Citations in Federal Court Filing Against Walmart

Description: Lawyers Rudwin Ayala, T. Michael Morgan (Morgan & Morgan), and Taly Goody (Goody Law Group) were fined a total of $5,000 after their Wyoming federal lawsuit filing against Walmart cited fake cases "hallucinated" by AI. Judge Kelly Rankin sanctioned them, removing Ayala from the case and noting attorneys must verify AI sources. The filing, flagged by Walmart’s legal team, led to its withdrawal and an internal review.
Editor Notes: Judge Kelly Rankin's "Order to Show Cause Why Plaintiffs’ Attorneys Should Not Be Sanctioned or Other Disciplinary Action Should Not Issue" of February 6th, 2025 can be accessed at the following URL: https://storage.courtlistener.com/recap/gov.uscourts.wyd.64014/gov.uscourts.wyd.64014.156.0_1.pdf. The later "Order on Sanctions and Other Disciplinary Action" of February 24th, 2025 can be accessed here: https://storage.courtlistener.com/recap/gov.uscourts.wyd.64014/gov.uscourts.wyd.64014.181.0_1.pdf.

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Alleged: Unspecified large language model developer developed an AI system deployed by Taly Goody , T. Michael Morgan , Rudwin Ayala , Morgan & Morgan and Goody Law Group, which harmed Taly Goody , T. Michael Morgan , Rudwin Ayala , Plaintiffs in Wyoming Walmart Hoverboard Lawsuit , Legal system , Judicial integrity , Clients of Morgan & Morgan and Clients of Goody Law Group.
Alleged implicated AI system: Unspecified large language model

Incident Stats

Incident ID
960
Report Count
11
Incident Date
2025-02-06
Editors

Incident Reports

Reports Timeline

+1
A Major Law Firm’s ChatGPT Fail
ChatGPT Blunder Hits America’s Largest Injury Firm+1
Lawyers in Walmart lawsuit admit AI 'hallucinated' case citations
Lawyers admit AI "hallucinated" cases in motion filed against WalmartAI making up cases can get lawyers fired, scandalized law firm warns+3
Sanctions on Lawyers for Filing Motion Containing AI-Hallucinated Cases
Lawyer booted from case after submitting AI-generated bogus brief
A Major Law Firm’s ChatGPT Fail

A Major Law Firm’s ChatGPT Fail

davidlat.substack.com

ChatGPT Blunder Hits America’s Largest Injury Firm

ChatGPT Blunder Hits America’s Largest Injury Firm

lawfuel.com

Lawyers in Walmart lawsuit admit AI 'hallucinated' case citations

Lawyers in Walmart lawsuit admit AI 'hallucinated' case citations

reuters.com

No. 42 law firm by head count sanctioned over fake case citations generated by AI

No. 42 law firm by head count sanctioned over fake case citations generated by AI

abajournal.com

Lawyers admit AI "hallucinated" cases in motion filed against Walmart

Lawyers admit AI "hallucinated" cases in motion filed against Walmart

5newsonline.com

AI making up cases can get lawyers fired, scandalized law firm warns

AI making up cases can get lawyers fired, scandalized law firm warns

arstechnica.com

Sanctions on Lawyers for Filing Motion Containing AI-Hallucinated Cases

Sanctions on Lawyers for Filing Motion Containing AI-Hallucinated Cases

reason.com

Judge fines lawyers in Walmart lawsuit over fake, AI-generated cases

Judge fines lawyers in Walmart lawsuit over fake, AI-generated cases

reuters.com

Federal Judge Sanctions Morgan & Morgan Attorneys for AI-Generated Fake Cases in Court Filing

Federal Judge Sanctions Morgan & Morgan Attorneys for AI-Generated Fake Cases in Court Filing

lawnext.com

AI fail: Morgan & Morgan lawyers cite 8 fictional cases, thanks to a chatbot | Commentary

AI fail: Morgan & Morgan lawyers cite 8 fictional cases, thanks to a chatbot | Commentary

orlandosentinel.com

Lawyer booted from case after submitting AI-generated bogus brief

Lawyer booted from case after submitting AI-generated bogus brief

washingtontimes.com

A Major Law Firm’s ChatGPT Fail
davidlat.substack.com · 2025

We’re all familiar with the infamous tale of the lawyers who filed a brief full of nonexistent cases—courtesy of ChatGPT, the AI tool that made up aka “hallucinated” the fake citations. In the end, Judge Kevin Castel (S.D.N.Y.) sanctioned t…

ChatGPT Blunder Hits America’s Largest Injury Firm
lawfuel.com · 2025

The legal profession’s ChatGPT reckoning has escalated beyond small-firm missteps. In a striking example of how AI can lead lawyers into a whole lot of mess, attorneys at Morgan & Morgan—the nation’s largest injury law firm with over 1,000 …

Lawyers in Walmart lawsuit admit AI 'hallucinated' case citations
reuters.com · 2025

Feb 10 (Reuters) - Lawyers representing plaintiffs in a lawsuit against Walmart (WMT.N), opens new tab over alleged injuries from a defective hoverboard toy said on Monday that they inadvertently included made-up cases generated by artifici…

No. 42 law firm by head count sanctioned over fake case citations generated by AI
abajournal.com · 2025

Updated: Lawyers from plaintiffs law firm Morgan & Morgan have been sanctioned for a motion that cited eight nonexistent cases, at least some of which were apparently generated by artificial intelligence.

U.S. District Judge Kelly H. Rankin…

Lawyers admit AI "hallucinated" cases in motion filed against Walmart
5newsonline.com · 2025

WYOMING, USA — Lawyers representing a Wyoming family in a lawsuit against Walmart and Jetson Electric Bikes admitted to using artificial intelligence to generate a pretrial motion after a federal judge said nearly all the cases they cited w…

AI making up cases can get lawyers fired, scandalized law firm warns
arstechnica.com · 2025

Morgan & Morgan---which bills itself as "America's largest injury law firm" that fights "for the people"---learned the hard way this month that even one lawyer blindly citing AI-hallucinated case law can risk sullying the reputation of an e…

Sanctions on Lawyers for Filing Motion Containing AI-Hallucinated Cases
reason.com · 2025

From Judge Kelly Rankin's Order on Sanctions and Other Disciplinary Action filed yesterday in Wadsworth v. Walmart Inc. (D. Wyo.):

Legal research has improved over time, going from the use of digest books to online databases like Lexis and…

Judge fines lawyers in Walmart lawsuit over fake, AI-generated cases
reuters.com · 2025

Feb 25 (Reuters) - Three lawyers suing Walmart in a personal injury lawsuit must pay fines totaling $5,000 for citing fake cases generated by artificial intelligence in a court filing, a federal judge ruled.

The lawyers, including two from …

Federal Judge Sanctions Morgan & Morgan Attorneys for AI-Generated Fake Cases in Court Filing
lawnext.com · 2025

You may have heard the news earlier this month that attorneys at plaintiffs law firm Morgan & Morgan — the 42nd largest U.S. law firm by headcount — were facing sanctions over their submission of court filings containing fake legal cases ge…

AI fail: Morgan & Morgan lawyers cite 8 fictional cases, thanks to a chatbot | Commentary
orlandosentinel.com · 2025

If you have any doubts about both the power and pitfalls of artificial intelligence, I have a cringe-inducing court case for you.

It involves the well-known Morgan & Morgan law firm filing a legal brief that cited nine cases as precedent th…

Lawyer booted from case after submitting AI-generated bogus brief
washingtontimes.com · 2025

A judge has kicked a lawyer off a case after he submitted a brief that contained false case citations fabricated by artificial intelligence.

U.S. District Judge Kelly H. Rankin also slapped a $3,000 fine on the lawyer, Rudwin Ayala, for vio…

Variants

A "variant" is an incident that shares the same causative factors, produces similar harms, and involves the same intelligent systems as a known AI incident. Rather than index variants as entirely separate incidents, we list variations of incidents under the first similar incident submitted to the database. Unlike other submission types to the incident database, variants are not required to have reporting in evidence external to the Incident Database. Learn more from the research paper.

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