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2384CV01461-BLS2 · Suffolk Superior Court / BLS2 · Order dated May 18, 2026
Published May 26, 2026
When AI Sanctions Followed The Lawyer
A Massachusetts Superior Court (Business Litigation Session) did not sanction for a new AI-generated filing. It denied T. Michael Morgan admission pro hac vice in a Massachusetts case after considering his recent District of Wyoming sanctions for filings that cited nonexistent cases generated by Morgan & Morgan's in-house AI platform, along with deficiencies in the Massachusetts pro hac vice record.1
Feb. 24, 2025
The prior sanction was Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. Feb. 24, 2025), identified as Morgan's District of Wyoming AI-citation sanction. The Massachusetts order describes Morgan as sanctioned for signing motions without reading them, after filings cited eight nonexistent cases generated by Morgan & Morgan's in-house AI platform in the earlier case.2
Professional-Liability Turn
The AI issue did not stay inside the original briefing error. In this record, it became part of a later assessment of whether the lawyer should be allowed into another court for another case.3
May 6-11, 2026
Before Morgan's motion, Shannon Pennock sought admission pro hac vice in the same case family. Judge Kenneth W. Salinger denied that motion without prejudice. The docket sheet gives the reason: local counsel had to file the motion and provide proof of full payment to the Massachusetts Board of Bar Overseers.4
Local Rule Problem
This is why the Pennock sequence matters: the later Morgan denial was not an AI-only ruling. It turned on both the Wyoming AI-citation sanction and Massachusetts admission mechanics, including local-counsel filing and BBO-payment proof.5, 7
May 12, 2026
Morgan's May 12 filing was a 28-page assented motion for admission pro hac vice under G.L. c. 221, sec. 46A. The May 18 order identifies Morgan as a Morgan & Morgan attorney practicing from Orlando, not a Massachusetts bar member, and in good standing in Florida and Kentucky. It also says plaintiffs were already represented by other Morgan & Morgan lawyers, including Ryan Lang, Garrett Lee, and Kathryn Barnett.6
May 18, 2026
Judge Salinger denied Morgan's pro hac vice motion. The May 18 order states that the court considered both the serious nature of Morgan's recent ethical violations in the District of Wyoming and Morgan's failure to comply with Massachusetts procedure in connection with his own pro hac vice motion.7
The Admission Hook
The story is not just an AI-citation story. It is an admission-discretion story: a prior litigation sanction became part of the court's decision whether an out-of-state lawyer could appear in a Massachusetts case.
Case-Law Impact
Reserved
Massachusetts and federal authority to be scoped separately. No doctrinal effect is asserted in this supplemental.
5.Source:MassCourts docket sheet for Wilder, 2384CV01461 The Pennock endorsement required local counsel to file the motion and provide proof of full payment to the Mass. BBO. The Pennock sequence is used to explain the admission-process context for the later Morgan denial, not to treat Pennock's defect as Morgan's filing defect.