Attorney AI use
Wadsworth v. Walmart Inc.
A lawyer used an apparent in-house AI tool and filed motions in limine in which eight of nine cited decisions did not exist.
Fines and admission revoked01
Case background
Material facts
Attorney Rudwin Ayala drafted motions in limine and uploaded them to MX2.law, which the court described as apparently an in-house Morgan & Morgan AI tool. His prompts asked the system to add Wyoming authority and a paragraph seeking to exclude evidence about an improperly discarded cigarette. The AI output supplied fabricated cases. Ayala did not verify them, and the supervising partner and local counsel whose electronic signatures appeared on the motions did not review the filings before submission.
02
The decision
The court’s ruling
The court fined the drafter $3,000 and revoked pro hac vice admission. It fined the supervising partner and local counsel $1,000 each.
Why it matters
What the decision means
The duty to verify legal authority predates AI. As the court explained, “As attorneys transition to the world of AI, the duty to check their sources and make a reasonable inquiry into existing law remains unchanged.” Research platforms can accelerate the work, but the lawyer must still read each cited decision and confirm that it exists, remains good law, and supports the proposition asserted. An internal AI system is not an authoritative source. The court added: “While technology continues to evolve, one thing remains the same—checking and verifying the source.”
Primary reading