Wadsworth v. Walmart Inc.

The timeline

• 2023A products-liability suit over an allegedly defective hoverboard proceeds in the District of Wyoming, with Morgan & Morgan attorneys appearing for the plaintiff.
• Late 2024Rudwin Ayala drafts motions in limine using the firm's in-house AI platform, MX2.law, prompting it to “add to this Motion in Limine Federal Case law from Wyoming setting forth requirements for motions in limine” and to “add more case law regarding motions in limine.”
• Early 2025The motions are filed bearing the signatures of Ayala, supervising partner T. Michael Morgan, and local counsel Taly Goody. Of nine cases cited, eight do not exist.
• 24 Feb 2025Judge Rankin issues the sanctions order, reported at 348 F.R.D. 489.
• 13 May 2025The District of Wyoming issues General Order 25-01, reminding all litigants that hallucinated citations are “strictly prohibited and subject to sanction”, about eleven weeks after Wadsworth.

What the AI did

MX2.law was not a consumer chatbot. It was the firm's own platform, offered to its lawyers as a professional resource. Asked to add Wyoming federal case law, it invented eight of the nine cases it supplied, and no one checked them against a real database before the motions were signed and filed. The firm's branding did not change what the tool was.

What the court did, and why

Judge Rankin held that Rule 11(b) was violated by every attorney who signed, not only the one who prompted the AI:

“a fake opinion is not ‘existing law’” and “blind reliance on another attorney can be an improper delegation of this duty.”, as quoted in the district's later General Order 25-01 (PDF) and secondary reporting

Ayala: $3,000 and revocation of his pro hac vice admission. Morgan and Goody: $1,000 each, for signing without verifying. The order also kept the AI question in proportion:

“When done right, AI can be incredibly beneficial for attorneys and the public.”, 348 F.R.D. at 493

What it changed

Wadsworth established that a firm-branded tool gets no exemption: the first pro hac vice revocation in this record, and supervisory liability for the partner who had not drafted a word. It also travels. In 2026, a Massachusetts court denied attorney T. Michael Morgan a pro hac vice application in Wilder v. Harvard, treating the Wyoming sanction as a recent ethical lapse, as reported. And the sanction became the district's rule: General Order 25-01 cites the principle that signing creates personal Rule 11 exposure regardless of which tool produced the text.

Sources

• Order text, 348 F.R.D. 489 (FindLaw mirror)
• Bob Ambrogi's original report (LawNext, 25 Feb 2025)
• D. Wyo. General Order 25-01 (court PDF, 13 May 2025)
• Attorney names, prompts and allocation as reported by the coverage above and by Legal AI Governance's tracker entry (verified there 5 May 2026).

Related

• The full sanctions record
• Mata v. Avianca, the case Wadsworth extends from consumer AI to firm AI
• Couvrette v. Wisnovsky, the record penalty
• Every verified AI standing order

Checked 4 August 2026. The order text is linked via mirror; underlying reporting is labeled where we rely on it. Information, not legal advice.