Attorney Morgan disclosed that he was sanctioned by the United States District Court for the District of Wyoming for violating Fed. R. Civ. P. 11(b) because he signed motions in limine without reading them and, as a result, permitted the filing of motions citing eight non-existent cases that had been hallucinated by Morgan & Morgan's in-house Artificial Intelligence ("AI") platform. [...] The Court is troubled by Morgan's demonstrated failure in the Wyoming case to live up to the ethical standards required of trial lawyers. [...] In sum, these further transgressions suggest that Morgan has not learned from the mistakes that he made in the Federal case in Wyoming, and that at least for now he cannot be trusted to comply with Massachusetts law and procedural rules.
The Wyoming case is already on this page: eight cases that do not exist, produced by Morgan & Morgan's own in-house AI platform, filed against Walmart, and a lawyer who signed the motions without reading them. This is what that cost him fifteen months later in a different state. T. Michael Morgan asked the Massachusetts Superior Court for permission to appear in litigation against Harvard, disclosed the Wyoming sanction as he was required to, and was refused. His clients already had three lawyers from his own firm on the case, so nothing turned on it except him. Decided 18 May 2026. The court gave two reasons and the second is the one worth noting, because it has nothing to do with AI: he had filed the motion without complying with the Massachusetts rule that governs those motions, which the court read as a second failure to check what he was signing. A sanction for fabricated citations does not end when the fine is paid. It goes on the disclosure a lawyer has to make every time they want to appear somewhere new.
