US | United States District Court for the District of Wyoming
Docket: 2:23-cv-00118-KHR • first instance
2025-02-24
Wadsworth v. Walmart Inc. — order on sanctions and other disciplinary action
LegalTool: mx2.law no human verificationfake case citationai-assisted drafting / research
I. Executive Summary
The court addressed motions in limine that cited numerous non-existent cases generated by an AI platform after counsel used an AI-assisted tool to insert Wyoming case law.
The court emphasized that attorneys must verify sources and that AI hallucinations do not excuse inaccurate filings.
It imposed monetary penalties and disciplinary action, including revocation of pro hac vice admission for the primary drafter.
II. Conduct Analysis
Counsel used an AI-enabled tool (mx2.law) to add case law to a draft motion and filed motions containing multiple hallucinated, non-existent citations without verifying their accuracy.
III. Legal Foundations
Fed. R. Civ. P. 11
court inherent authority
IV. Key Facts
1) Motions in limine filed on 2025-01-22 cited nine cases, eight of which did not exist.
2) The court issued an order to show cause; the motions were withdrawn the next day.
3) Counsel admitted the citations were hallucinated by an AI platform and that the filings were not verified before submission.
4) The court evaluated each attorney’s role, including the use of mx2.law to generate the citations.
V. Consequences & Sanction
1) The primary drafter’s pro hac vice admission was revoked and he was removed as counsel of record.
2) Monetary penalties were imposed on three attorneys and payable to the court registry within a fixed deadline.