https://www.abajournal.com/news/article/no-42-law-firm-by-headcount-could-face-sanctions-over-fake-case-citations-generated-by-chatgpt Toggle navigation [aba-log] * My ABA * Events * CLE Marketplace * Shop ABA * Member Directory * Join * Log In ABA Journal * News + Latest News + Topics + Features * Latest Issue * Podcasts + Asked and Answered + Legal Rebels + Modern Law Library * Columnists + Bryan Garner on Words + Erwin Chemerinsky + Mind Your Business + Your Voice + How I Won the Case + My Path to Law + Survival Guide, Esq. + Supreme Court Report + 10 Questions + What's on the Shelf? + Nicole Black + Ari Kaplan + Adam Banner + Randy Maniloff + Marcel Strigberger * Members Who Inspire [ ] Submit 1. Home 2. Daily News 3. No. 42 law firm by head count could face... Technology No. 42 law firm by head count could face sanctions over fake case citations generated by AI By Debra Cassens Weiss February 10, 2025, 10:30 am CST * * # * * Tweet * * Email * Print ChatGPT typing on computer Lawyers from plaintiffs law firm Morgan & Morgan are facing possible sanctions for a motion that cited eight nonexistent cases, at least some of which were apparently generated by artificial intelligence. (Image from Shutterstock) Updated: Lawyers from plaintiffs law firm Morgan & Morgan are facing possible sanctions for a motion that cited eight nonexistent cases, at least some of which were apparently generated by artificial intelligence. In a Feb. 6 order, U.S. District Judge Kelly H. Rankin of the District of Wyoming told lawyers from Morgan & Morgan and the Goody Law Group to provide copies of the cited cases, and if they can't, to show cause why they shouldn't be sanctioned. Law360 and Original Jurisdiction have coverage. The cases cited by the court had been "hallucinated" by an internal AI platform and were not legitimate, the firms said in a Feb. 10 response to the show-cause order. "This matter comes with great embarrassment and has prompted discussion and action regarding the training, implementation and future use of artificial intelligence within our firm," the response said. "This serves as a cautionary tale for our firm and all firms, as we enter this new age of artificial intelligence." The law firms' brief had cited nine cases, but Rankin could locate only one of them. Some of the citations did lead to cases under different names. The lawyers' motion also included a description of the governing legal standard that was "peculiar," Rankin said. The motion correctly cited a federal rule of evidence but then went on to say "Wyoming caselaw reinforces these principles." To support the assertion about Wyoming caselaw, the motion cited fake federal district court cases. "Notwithstanding this slight inconsistency, experienced litigators like plaintiffs' counsel should know that this court is a federal court, and therefore federal procedural law governs evidentiary issues," Rankin wrote. Morgan & Morgan is ranked No. 42 in the United States based on firm head count, according to Original Jurisdiction, which cited figures from the American Lawyer. The Goody Law Group appears to be a small firm based in California. "Moral of the story: Lawyers at large firms can misuse ChatGPT as well as anyone," wrote Above the Law founder David Lat at Original Jurisdiction. The case involves a hoverboard sold by Walmart that allegedly exploded and caught fire, according to Law360. The lawyers who signed the now-withdrawn motion with the alleged fake cites were Rudwin Ayala and T. Michael Morgan of Morgan & Morgan and Taly Goody of the Goody Law Group. They did not immediately respond to ABA Journal emails seeking comment. Morgan and Goody did not respond to Journal voicemails. A person who answered a call at Morgan & Morgan could not locate Ayala in the directory. The communications director for Morgan & Morgan emailed the Journal a copy of the show-cause response after it was filed. Updated Feb. 12 at 8:50 a.m. to report on the response to the show-cause order. [INS::INS] Write a letter to the editor, share a story tip or update, or report an error. --------------------------------------------------------------------- Related topics: States | Law Firms | Judiciary | Practice Management | Ethics | Technology | Wyoming | Practice Technology | Career & Practice | Artificial Intelligence & Robotics --------------------------------------------------------------------- You might also like: * Using Westlaw headnotes to train competing AI legal research program isn't fair use, judge rules * Should we expect new regulations on data privacy and consumer protection? * Misuse of digital replicas should be addressed by federal law, ABA House says * How agentic AI services are revolutionizing contract management and compliance * Access to Justice 2.0: How AI-powered software can bridge the gap --------------------------------------------------------------------- Most Read 1. No. 42 law firm by head count could face sanctions over fake case citations generated by AI 2. ABA President Bay denounces 'chaotic' attacks on the rule of law 3. Feds seek forfeiture of law office over lawyer's alleged role in 'DWI Enterprise' 4. 3 lawyers with 'elite establishment credentials' have joined Musk's DOGE effort, report says 5. BigLaw firm tones down diversity references on website, citing 'fluctuating internal and external expectations' Latest featured news ... --------------------------------------------------------------------- --------------------------------------------------------------------- Topics: Career & Practice [newyork-pr] Senior DOJ officials resign after order to drop case against NYC Mayor Eric Adams Complete list of topics ... [Choose a topic to explore ... ] Your Voice [Sameer_Som] Abraham Lincoln: A model for ethical leadership Articles and commentary ... Podcasts [data_priva] Should we expect new regulations on data privacy and consumer protection? More podcasts ... --------------------------------------------------------------------- --------------------------------------------------------------------- ABA Journal logo. * ABA Journal * American Bar Association * 321 N Clark St * Chicago, IL 60654-7598 * 800-285-2221 * 312-988-5522 * Features * Photo Galleries * Magazine Back Issues * Magazine Digital Edition * RSS Feed * Search * Corrections * About the ABA Journal * Authors * Code of Conduct * Contests * Privacy Policy * California Privacy Rights * Terms of Use * Contact the ABA Journal * Advertise * Email Newsletters * Letters to the Editor * Reprints * Tips & Pitches * [facebook] * [twitter] * [linkedin] * [pinterest] * [instagram] * [youtube] * [feeds] Copyright 2025 American Bar Association. All rights reserved.