The legal industry’s adoption of AI tools has led to several high-profile incidents of attorneys submitting AI-generated false citations in court documents. Morgan & Morgan, a major law firm with over 1,000 lawyers, recently faced embarrassment when two of its attorneys cited non-existent court cases generated by AI in a lawsuit against Walmart.
The incident in detail: A federal judge in Wyoming discovered nine instances of fake case law in court filings submitted by Morgan & Morgan attorneys in January 2025.
- The attorneys, when confronted, blamed an “internal AI tool” for generating the false citations and requested leniency from the judge
- The case in question involves a lawsuit against Walmart regarding a hoverboard that allegedly caused a house fire
- The judge is still considering whether to impose sanctions on the attorneys involved
Firm’s response to the crisis: Morgan & Morgan issued an urgent email to all attorneys emphasizing the importance of verifying AI-generated legal citations.
- The firm stopped short of banning AI tools, instead implementing a verification requirement
- Attorneys must now acknowledge AI-related risks by checking a box when using the firm’s internal AI tool
- The email stressed that attorneys’ professional integrity and reputation depend on proper verification of AI-generated content
Industry context and implications: This incident is part of a broader pattern of AI-related mishaps in the legal profession.
- At least seven cases in the past two years have involved lawyers being questioned or disciplined for improper AI use
- Andrew Perlman, dean of Suffolk University’s law school, categorized the use of AI-generated citations without verification as “pure and simple” incompetence
- The legal industry continues to grapple with balancing AI’s efficiency benefits against its potential to generate false information
Systemic challenges: The incident highlights fundamental issues with AI implementation in professional settings.
- AI models can present false information with convincing authority
- The automation of tasks often leads to decreased human vigilance
- Similar challenges have emerged in other industries, including self-driving cars and news agencies
Looking ahead: The automation paradox: While firms like Morgan & Morgan implement superficial solutions such as acknowledgment checkboxes, the fundamental challenge remains: as AI tools become more integrated into legal work, the tension between efficiency and accuracy will likely lead to more such incidents unless more robust verification systems are developed.
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