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Morgan & Morgan warns lawyers of AI-fabricated legal citations

Two lawyers at Morgan & Morgan used generative AI tools that fabricated non-existent case citations in a lawsuit against Walmart, leading a federal judge in Wyoming to consider sanctions. The incident prompted the law firm to warn its 1,000+ attorneys about AI hallucinations in legal research and sparked broader concerns about AI-generated misinformation in court filings across the US.

19 February 2025 Β· Morgan & Morgan Β· Reliability and hallucination
19 February 2025
AII-1002-684232 sources ↓
Quick facts
Category
Reliability and hallucination
Country
United States
Source
news.abplive.com
Date
19 February 2025
Drafted by
Raidu Incident Detection

What happened

Two attorneys at Morgan & Morgan cited non-existent case law in a lawsuit against Walmart involving an allegedly defective hoverboard toy. One attorney admitted to using an AI tool that produced fictitious legal references and called it an unintentional error.

A federal judge in Wyoming considered sanctioning the two lawyers for the fabricated citations. Morgan & Morgan subsequently issued an urgent warning to its over 1,000 attorneys about the dangers of relying on generative AI for legal research, emphasizing that AI-generated case law can be entirely fabricated.

Reported impact

The incident highlighted broader risks for the legal profession, with at least seven instances of lawyers being questioned or disciplined for using AI-generated legal citations over the past two years. The American Bar Association warned its 400,000 members that attorney ethics rules require lawyers to vet and stand by all court filings, including unintentional misstatements produced through AI, or risk disciplinary action.

Index analysis

Generative AI systems generate responses based on statistical patterns learned from large datasets rather than by verifying facts, sometimes producing false information known as 'hallucinations' in the industry. The systems can confidently present fabricated information, posing particular risks in legal contexts where accuracy of citations is mandatory.

Governance controls

Attorney ethics rules require lawyers to vet and stand by their court filings or risk being disciplined. Morgan & Morgan warned its team that submitting false information in court filings could result in termination.

Classification

Category
Reliability and hallucination
Industry
Government, security and defence
Country
United States
Harm status
Actual harm
Intent
Unintentional
Timing
Unknown
Harm types
Reputational
Harmed
Business
Failure modes
Hallucination, Fabricated citation
Consequences
Litigation
AI systems
Generative AI legal research tools
Regulations
FCRA (cited)

Sources and evidence

This record was researched and written by the Index, based on the following original reporting.

news.abplive.com
Using AI To Find Case Citations To Submit In Court? You Might Be In For Big Trouble, Find Out How
19 February 2025
The News International
US lawyers in hot water over AI-generated court filings
19 February 2025