“As all lawyers know (or should know), it has been documented that AI sometimes invents case law, complete with fabricated citations, holdings, and even direct quotes,” his letter said. “As we previously instructed you, if you use AI to identify cases for citation, every case must be independently verified.”
While Harry Surden, a law professor who studies AI legal issues, told Reuters that “lawyers have always made mistakes,” he also suggested that an increasing reliance on AI tools in the legal field requires lawyers to increase AI literacy to fully understand “the strengths and weaknesses of the tools.” (A July 2024 Reuters survey found that 63 percent of lawyers have used AI and 12 percent use it regularly, after experts signaled an AI-fueled paradigm shift in the legal field in 2023.)
At Morgan & Morgan, it has become clear in 2025 that better AI training is needed across its nationwide firm. Morgan told the court that the firm’s technology team and risk management members have met to “discuss and implement further policies to prevent another occurrence in the future.”
Additionally, a checkbox acknowledging AI’s potential for hallucinations was added, and it must be clicked before any attorney at the firm can access the internal AI platform.
“Further, safeguards and training are being discussed to protect against any errant uses of artificial intelligence,” Morgan told the court.
Whether these efforts will help Morgan & Morgan avoid sanctions is unclear, but Ithayakumar suggested that on par with sanctions might be the reputational loss to the firm’s or any individual lawyer’s credibility.
“Blind reliance on AI is equivalent to citing an unverified case,” Ithayakumar told lawyers, saying that it is their “responsibility and ethical obligation” to verify AI outputs. “Failure to comply with AI verification requirements may result in court sanctions, professional discipline, discipline by the firm (up to and including termination), and reputational harm. Every lawyer must stay informed of the specific AI-related rules and orders in the jurisdictions where they practice and strictly adhere to these obligations.”
