Morgan & Morgan lawyers cite eight fabricated cases in Wyoming federal court filing
Morgan & Morgan, the nation's largest injury law firm, filed a federal court brief citing nine cases as legal precedent in a hoverboard injury lawsuit against Walmart, but eight of the cases were entirely fabricated by ChatGPT and did not exist. A federal judge issued an order demanding the firm explain the fabricated citations or face sanctions under Rule 11 and the court's inherent authority.
What happened
On January 22, 2025, Morgan & Morgan filed motions in limine in Wyoming federal court that cited nine cases as precedent in a lawsuit involving a hoverboard injury claim against Walmart. Eight of the nine cases were entirely fictional and did not exist in court records or legal databases, including fabricated cases like Meyer v. City of Cheyenne with invented Westlaw identifiers. A Morgan & Morgan lawyer had used ChatGPT to generate the case citations, which the AI system hallucinated.
When Walmart's defense counsel reviewed the filings, they discovered that most cited cases were unlocatable and alleged ChatGPT generated the phantom citations. Judge Kelly Rankin issued an order on February 7 demanding attorneys Rudwin Ayala (Morgan & Morgan), Taly Goody (Goody Law Group), and Timothy Michael Morgan (Morgan & Morgan) produce valid copies of the cases by February 10 or face sanctions under Rule 11, § 1927, and the court's inherent authority.
Reported impact
Morgan & Morgan, the nation's largest injury law firm with over 1,000 lawyers, faces potential sanctions for the fabricated citations. The firm's founder John Morgan stated: 'One of our lawyers relied solely on A.I. and mucked up,' and the lead attorney, Mike Morgan, issued a declaration apologizing to the court and opposing counsel.
Index analysis
The incident echoes a 2023 case involving Levidow, Levidow & Oberman but is notable because Morgan & Morgan's substantial resources and ranking as the 42nd largest firm by headcount make the oversight harder to justify. Judge Rankin cited Mata v. Avianca (S.D.N.Y. 2023)—another ChatGPT hallucination case—as a template for accountability, and courts are increasingly mandating sworn declarations explaining AI use in filings.
The case highlights systemic risks in relying on AI without verification, particularly when only one valid case (United States v. Caraway, 10th Cir. 2008) existed among the nine cited. Legal analysts and the tech industry have emphasized the need for lawyers to cross-check AI-generated citations against authoritative platforms like Westlaw or LexisNexis before submission.
Governance controls
Judge Rankin required all three named attorneys to detail their involvement in drafting and reviewing the filing by February 13, establishing individual accountability. Morgan & Morgan's declaration acknowledged that 'there are no shortcuts in law' and emphasized that artificial intelligence 'is a tool which must be used carefully.'
Classification
Sources and evidence
This record was researched and written by the Index, based on the following original reporting.