Three lawyers sanctioned after filing AI-generated fictitious citations
A Wyoming federal court fined three lawyers a total of $5,000 and removed the drafting lawyer from Wadsworth v. Walmart after a January 2025 filing cited eight nonexistent cases. The order identifies MX2.law as the drafting tool, records failure to verify its output and credits subsequent remedial steps.
- AI system
- MX2.law
- Morgan & Morgan
- Occurred
- 22 Jan 2025 to 24 Feb 2025
- Reported
- 24 February 2025
- Event location
- Unknown
- What the AI did
- Communicated with the person · Acted on the person’s behalf
- Reported harm
- Legal HarmProfessional Harm
- Whose AI use
- Their own AI use · Someone else’s AI use
- Setting
- Justice · Work
- Evidence
- AI involvement supported · Causal attribution supported · 1 source
- 2 claims: 2 documented. 1 open question
- People reported harmed
- At least 3 people
Reported harm
The court imposed $3,000, $1,000 and $1,000 penalties and revoked the drafting lawyer’s admission to this case.
What remains unknown
- Underlying model, precise drafting day and eventual payment of penalties are unknown.
What the evidence supports
AI involvement: supported. Court order identifies the tool and records the drafter’s prompts.
2 claims: 2 documented. What the statuses mean
Documented The order records a 22 January filing containing eight fictitious citations generated with MX2.law and not verified before filing.
Causal attribution. The order records counsel’s admissions and the court’s findings.
- lawnext.com(opens in new tab) supports · English
ECF 181, pages 3–5, Procedural Facts and How the Fake Cases Were Generated.
Documented The court fined three lawyers a total of $5,000, removed the drafter from the case and treated withdrawal, candour, fee reimbursement and new safeguards as mitigation.
Causal attribution. Sanctions address professional verification duties; the record does not assign sole responsibility to AI.
- lawnext.com(opens in new tab) supports · English
ECF 181, pages 5–6, Remedial Steps; pages 12–17, individual sanctions and conclusion.
Sources
1 source inspected. Sources that repeat one account do not corroborate each other.
- Wadsworth v. Walmart, ECF 181, sanctions order filed 24 February 2025(opens in new tab)
s1 · lawnext.com · Court order · English · Inspected · Primary
How the sources were read, and where the events happened
Event countries: Unknown. Affected-person countries: Unknown. Court countries: United States.
Wyoming federal court. Drafting location and lawyers’ residence not established.
Reviewed for publication 2026-09-29: A filed order establishes the sanctions and AI-assisted drafting, with mitigation retained.
People reported harmed in this case
At least 3 people
1 AI participant · 2 other people harmed
Three individually sanctioned lawyers; one drafted with AI. Clients and institutional costs are not included in this minimum.
Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.
Cite this case
Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.
APA
NOPE. (2026). Three lawyers sanctioned after filing AI-generated fictitious citations. AI incidents. https://nope.net/incidents/2025-wadsworth-lawyers-sanctioned-ai-fabricated-citations
BibTeX
@misc{2025_wadsworth_lawyers_sanctioned_ai_fabricated_citations,
title = {Three lawyers sanctioned after filing AI-generated fictitious citations},
author = {NOPE},
year = {2026},
howpublished = {AI incidents},
url = {https://nope.net/incidents/2025-wadsworth-lawyers-sanctioned-ai-fabricated-citations}
} Related cases
SDT strikes solicitor Abhishek Kumar off the Register of Foreign Lawyers after AI-generated false citations in his SRA defence
On 25 August 2026 the Solicitors Disciplinary Tribunal struck Abhishek Kumar off the Register of Foreign Lawyers after finding proved that his 12 March 2026 Answer to the SRA's Rule 12 Statement contained misleading quotations and citations produced with generative AI — including a non-existent 'SRA v Chan [2020] EWHC 1502' and a miscited 'SRA v James, MacGregor & Naylor [2018] EWCA Civ 1420' that is actually an intellectual-property case — and that his 9 April 2026 email admitting AI use was itself AI-drafted with further errors. The tribunal said it would have struck him off on that allegation alone; the parallel ground was his January 2024 conviction under s.21 of the Immigration, Asylum and Nationality Act 2006. This is the SDT's first case on a lawyer's use of AI, per the SRA's counsel.
Fee suit against the City of Aberdeen (N.D. Miss.): four attorneys on both sides sanctioned after AI tools produced fabricated case citations; trial cancelled and both litigants left without counsel
In a fee dispute between a Louisiana attorney and the City of Aberdeen, Mississippi, briefs filed for both sides in late 2025 cited six cases that do not exist. The attorneys admitted the citations came from unverified AI use: the plaintiff's out-of-state counsel, Kathleen M. Wilson, drafted her filing with an AI drafting program called 'First Drafts', and the City's out-of-state counsel, Kathryn Y. Williams, used an in-house AI legal research tool. Senior Judge Sharion Aycock stayed the case and cancelled the March 2026 trial, then on 8 June 2026 revoked both attorneys' pro hac vice admissions, barred them from the district for two years and fined them $2,500 and $3,500, and disqualified and fined the two local counsel who had signed the filings. Both litigants were left without counsel and given 60 days to find new representation.
New Mexico Supreme Court fines attorney Stephen Aarons $5,000 and removes him from a murder appeal over ChatGPT-fabricated testimony
Santa Fe defense attorney Stephen Aarons used ChatGPT (OpenAI's o3) on a Rev.com transcript and the record to draft briefing in the murder appeal of Oscar Renee Sandoval; the brief contained fabricated witnesses and testimony (including police officers 'Michelle Amarillo' and 'Sanchez' and invented testimony attributed to real people) and misdescribed real precedents. After a 21 August 2026 show-cause hearing at which Aarons admitted he had not verified the output, the New Mexico Supreme Court's written order of 9 September 2026 held him in direct contempt, fined him $5,000 payable to the State Bar Client Protection Fund within 30 days, removed him from the case, barred him from appearing before the court pending a disciplinary-board referral, struck the filed briefs and reassigned the appeal to the public defender.
Stephens County, Oklahoma: according to the district attorney, Judge Lawrence Wheeler told state investigators that a November 2025 order in a paternity and custody case, which denied a parent's request for a psychological evaluation and reprimanded that parent's attorney, cited at least two nonexistent cases produced by ChatGPT; the order was vacated after the attorney challenged it
In November 2025 Stephens County Associate District Judge Lawrence Wheeler issued an order in a child paternity and custody case that denied one parent's request for a psychological evaluation of the other parent and reprimanded the requesting parent's attorney 'for stooping to such frivolous trial tactics'. The attorney challenged the order at the Oklahoma Supreme Court in February 2026, telling the justices that it relied on two cases that do not exist; the challenge was dismissed in March after Wheeler vacated the order, and he is no longer on the case. According to a 17 August 2026 letter from the Stephens County district attorney, Wheeler told the Oklahoma State Bureau of Investigation that he used ChatGPT for research and wrote the order himself, and that at least two citations in it produced by ChatGPT do not exist. The mother in the case told News 9 that learning the order's citations were allegedly fabricated was alarming because it concerned the custody of a child. The attorney general's office declined criminal prosecution; judicial discipline remains possible.
If you or someone you know is struggling, free and confidential support is available. Find a helpline near you at Signpost.