Wadsworth v. Walmart: AI-fabricated case citations in federal court filing
Morgan & Morgan attorneys filed a federal court motion citing nine cases, eight of which were fabricated by the firm's in-house AI platform, and were sanctioned.
What happened
In Wadsworth v. Walmart Inc., No. 2:23-CV-118-KHR, in the U.S. District Court for the District of Wyoming, attorneys from the firm Morgan & Morgan filed motions in limine dated January 22, 2025 that cited nine cases, eight of which did not exist. The nonexistent citations had been generated by MX2.law, an in-house AI platform used by the firm, rather than a public tool. On February 24, 2025, U.S. District Judge Kelly H. Rankin issued an order sanctioning three attorneys. Rudwin Ayala, who drafted the motion, was fined $3,000 and had his pro hac vice admission revoked. Supervising attorney T. Michael Morgan was fined $1,000, and local counsel Taly Goody of the Goody Law Group was fined $1,000. The court declined to sanction the firm itself, citing the firm's remedial steps and the attorneys' candor.
What the agent did
The MX2.law AI platform generated eight nonexistent case citations. Human attorneys then incorporated those fabricated citations into a court filing and filed it; the filing was done by the lawyers, not automatically by the AI.
The irreversible effect
A motion containing eight fabricated case citations was filed on the public docket of a federal court, leading to monetary sanctions against three attorneys and the revocation of one attorney's pro hac vice admission.
Root cause
An attorney relied on AI-generated legal research without verifying that the cited cases existed, and supervising and local counsel signed and filed the motion without independently checking the citations.
How a maker-checker control would have refused it
This was a human-final-action case: the AI produced fabricated citations but attorneys chose to file the document, so no automated control was in place or bypassed. Hypothetically, a maker-checker gate requiring a human or automated verification step to confirm each cited case exists in a legal database before a filing could be submitted would have caught the eight nonexistent cases. The supervising attorney and local counsel functioned as nominal checkers but did not perform the verification, so the checker role existed in form without independent review.
Runnable reproduction
A runnable reproduction for this entry is in progress.
Accuracy and corrections
This entry describes a publicly reported incident and is compiled from the primary sources listed above. Where an account is a legal allegation rather than an established finding, the entry labels it as such. Summaries can still contain errors. If you can document a correction, email hello@makerchecker.ai and we will review and correct it, with the change noted, within 14 days.
See it for yourself
Reading is one thing. Watch it block an agent.
One command starts the demo: an agent stopped from signing off its own work, and the signed evidence file an inspector can check for themselves.
Designed against the rules your auditors already enforce.