The bar stems from Morgan's involvement in a 2025 Wyoming federal case against Walmart, where he and other attorneys were sanctioned for filing motions containing multiple fake case citations generated by artificial intelligence. The Wyoming court found the filings cited nonexistent legal authorities. Salinger cited this history in refusing Morgan's admission, signaling concern about his judgment and reliability going forward.
The Harvard matter involves families suing over the alleged theft of body parts donated to the medical school—a case with significant public attention. The ruling reflects a hardening judicial stance on AI-generated false citations as a professional responsibility violation. Courts are now treating such errors as serious misconduct, particularly when the same attorney seeks to appear in another high-profile matter after prior sanctions. Attorneys should expect judges to scrutinize AI-related filing errors more closely and to impose barriers to future practice when prior incidents suggest inadequate remediation.