Lawyers Sanctioned for Citing AI-Generated Fake Cases
In a cautionary tale for the legal profession, three lawyers from Morgan & Morgan were sanctioned by a federal district court for submitting motions that cited AI-generated, fabricated case law. This incident underscores the critical need for careful scrutiny of AI-produced information, particularly in legal contexts.
According to Linn F. Freedman of Robinson & Cole LLP, “In another ‘hard lesson learned’ case, on Monday, February 24, 2025, a federal district court sanctioned three lawyers from the national law firm Morgan & Morgan for citing artificial intelligence (AI)-generated fake cases in motions in limine.”
Of the nine cases cited, eight were nonexistent. Despite two lawyers not being directly involved in drafting the motions, all three electronically signed the documents before filing. Upon being questioned by opposing counsel, the drafting attorney admitted to using MX2.law, an in-house AI database for legal research, to populate the motions with case law. The attorney also admitted that it was their first time using AI in this manner and that they failed to verify the accuracy of the AI platform’s output.
Fortunately, Morgan & Morgan acted swiftly, withdrawing the motions, and informing the court. The firm also reimbursed the defendant for attorney’s fees and implemented new internal policies, safeguards, and training to prevent a recurrence. The court sanctioned each of the three lawyers involved. The attorney who drafted the motions received a $3,000 fine while the other two were fined $1,000 each.
This is a timely reminder of the risks associated with using generative AI tools in legal work. While AI can be a useful resource, it cannot replace the need for thoroughness and due diligence. The court’s ruling emphasized that “As attorneys transition to the world of AI, the duty to check their sources and make a reasonable inquiry into existing law remains unchanged.”
This case serves as a stark warning to all legal professionals: always verify the output of AI-generated materials before submitting them to the court or relying upon them in any legal context. The use AI can bring efficiency, but it does not absolve attorneys of their duty to present accurate and verifiable information.
