Source: Massachusetts Lawyers Weekly

A Massachusetts Superior Court judge denied T. Michael Morgan’s motion to appear pro hac vice in the Harvard morgue class action, finding deficiencies in his disclosure and procedural compliance after a Wyoming judge sanctioned filings that included multiple AI-generated, nonexistent case citations. The Wyoming U.S. District Court order by Judge Kelly H. Rankin found nine cited cases in motions filed there, eight of which did not exist and had been produced by Morgan & Morgan’s in‑house AI tool, MX2.law; Rudwin Ayala received a $3,000 fine and revocation of his pro hac vice status in Wyoming, while Rankin concluded Morgan had violated Rule 11 though to a lesser degree.

Superior Court Judge Kenneth W. Salinger, on May 18, exercised discretion to deny Morgan’s Massachusetts pro hac vice application, faulting Morgan for insufficient disclosure about the Wyoming sanction, failing to show he changed his practices to ensure future filings over his signature would be reviewed, improperly designating himself as movant, and paying the incorrect pro hac vice fee. The judge emphasized the ethical obligation of supervising lawyers to verify authorities, described the omission as serious, and concluded that the combined transgressions meant Morgan could not be trusted to comply with Massachusetts law and procedural rules; commentators cited the decision as reflecting heightened judicial scrutiny of AI-assisted drafting and attorney supervision obligations.