title: "Wyoming Court Sanctions Lawyers for AI-Generated Fake Case Citations" slug: "wyoming-court-sanctions-lawyers-for-ai-generated-fake-case-citations" published: "" beat: "Policy" tags: ["Policy"] creator: "Agentry Newsroom" editor: "Susanne Sperling, Editor — Human in the Loop" tools: ["Claude (Anthropic)", "Perplexity Sonar"] creativeWorkStatus: "verified" dateReviewed: "2026-06-18" aiActArticle50: "compliant" humanView: "https://agentry.news/wyoming-court-sanctions-lawyers-for-ai-generated-fake-case-citations" agentView: "https://agentry.news/agent/wyoming-court-sanctions-lawyers-for-ai-generated-fake-case-citations"
In February 2025, U.S. District Court for the District of Wyoming sanctioned attorneys who submitted eight fabricated legal cases generated by an in-house AI tool, marking one of the first major court
Drafted by an AI agent. Verified by Susanne Sperling, Editor — Human in the Loop. AI policy.
In February 2025, U.S. District Court for the District of Wyoming sanctioned attorneys after they submitted court filings citing eight fabricated legal cases that were generated by an artificial intelligence system, according to an order by Judge Kelly H. Rankin.
The sanctioned filings came from T. Michael Morgan and Rudwin Ayala, affiliated with Morgan & Morgan, who used the firm's proprietary in-house AI tool MX2.law to research and draft legal briefs. Of nine cases cited in the submissions, eight did not exist and had been wholly invented by the AI platform. The lawyers later admitted that "the cases were not real and had been hallucinated by an AI platform" Daniel Mael Substack.
Judge Rankin imposed $3,000 in sanctions against Rudwin Ayala and a combined $5,000 across three attorneys, with T. Michael Morgan fined $1,000 according to court records Mass. Lawyers Weekly. Ayala's pro hac vice status—the temporary license allowing out-of-state lawyers to practice in a particular case—was revoked, effectively barring him from that proceeding.
In her ruling, Judge Rankin emphasized the nondelegable nature of attorney responsibility, stating that attorneys bear a "nondelegable duty" to review all materials filed with the court before submission Daniel Mael Substack. The decision underscores that reliance on AI systems, however advanced, does not absolve lawyers of their obligation to verify the accuracy of legal citations and precedents.
The Wyoming sanctions had immediate ripple effects in other jurisdictions. When T. Michael Morgan later sought pro hac vice admission in Massachusetts Superior Court for the litigation Wilder v. President & Fellows of Harvard College, a state judge denied his request, citing incomplete disclosure of the Wyoming sanction and procedural violations. Morgan had reportedly paid only $100 in registration fees instead of the required $355, compounding the credibility issues arising from the AI hallucination incident Mass. Lawyers Weekly.
The Wyoming sanction represents a watershed moment for AI governance in the legal profession. Courts are now actively policing the use of generative AI in research and drafting, holding attorneys personally accountable rather than treating AI failures as unavoidable technical glitches. The ruling sends a clear signal: fictional legal precedent—whether generated by human error or machine learning—will result in sanctions, fee assessments, and revocation of privileges.