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If you wanted a single case to put on the cover of every CLE brochure for the next five years, Wadsworth v. Walmart Inc. would do nicely. A hoverboard explodes in a Wyoming family’s home. The family sues. Their lawyers — from America’s loudest plaintiffs’ firm, no less — file a motion in limine citing nine cases. Eight of them do not exist. They have never existed. They were, in the now-familiar verb of our age, hallucinated.

And so on 24 February 2025, U.S. District Judge Kelly H. Rankin handed down what is shaping up to be the defining American sanctions order of the generative-AI era. Rudwin Ayala — the Morgan & Morgan associate who actually fed the brief into the firm’s in-house AI tool, charmingly named MX2.law — lost his pro hac vice admission and was fined $3,000.

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