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}
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