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Attorneys – AI – Pro hac vice appearance | Massachusetts Lawyers Weekly.Superior Court/Business Litigation Session Mass.Lawyers Weekly Staff//May 25, 2026// Superior Court/Business Litigation Session Mass.Lawyers Weekly Staff//May 25, 2026// Where an out-of-state attorney has filed a motion on his own behalf seeking permission to appear for the plaintiffs, that motion should be denied because (1) it was filed in violation of G.L.c.221, §46A, and Supreme Judicial Court Rule 3:15 and (2) the attorney has been sanctioned in federal court in Wyoming for his role in submitting hallucinated case citations.“Attorney T.Michael Morgan is a member the law firm Morgan & Morgan; he practices out of the firm’s Orlando, Florida office.Morgan has filed a motion on his own behalf seeking permission to appear for the plaintiffs in this action.Morgan is not a member of the Massachusetts bar, but represents that he is an active member in good standing of the Florida and Kentucky bars.… “Attorney Morgan disclosed that he was sanctioned by the United States District Court for the District of Wyoming for violating Fed.11(b) because he signed motions in limine without reading them and, as a result, permitted the filing of motions citing eight non-existent cases that had been hallucinated by Morgan & Morgan’s in-house Artificial Intelligence (‘AI’) platform.See Wadsworth v.Walmart Inc., 348 F.R.D.24, 2025).“The Court will exercise its discretion to deny Attorney Morgan’s motion for permission to appear in this case pro hac vice.The Court is troubled by Morgan’s demonstrated failure in the Wyoming case to live up to the ethical standards required of trial lawyers.Its concern is heightened by Morgan’s decision to practice law in Massachusetts without permission, by filing his motion in violation of the statute (G.L.c.221, §46A) and the Massachusetts Supreme Judicial Court rule (SJC Rule 3:15) that govern pro hac vice motions.In light of Morgan’s recent misconduct in Federal court, and his disregard of Massachusetts law and procedural rules in this case, the Court is not persuaded that Morgan should be granted permission to appear before the Massachusetts Superior Court.… “Attorney Morgan’s role in submitting hallucinated case citations to a Federal District Court, and his failure in that action to review motions that he allowed to be filed over his signature, provide ample grounds for denying his request to appear pro hac vice in this case.… “Morgan’s ethical transgression in this Wyoming case was quite serious.Trial lawyers cannot file legal papers supported by fake case citations.More senior attorneys have just as much responsibility as any lawyers whom they supervise to review motions and legal memoranda and ensure that they are accurate and do not contain made up case law or evidence.… “Morgan’s failure ‘to take basic, necessary precautions that likely would have averted the submission of’ fake case citations to the Federal court in Wyoming ‘is categorically unacceptable.’ … “Filing motions riddled with made-up case law, or permitting a colleague to do so over one’s signature, reflects a ‘lack of diligence and apparent failure to take seriously the responsibility of conducting litigation in compliance with the rules of civil procedure.’ … Doing so inadvertently is no excuse.“Although Attorney Morgan disclosed the recent Federal sanctions against him in his motion, Morgan makes no attempt to show that he has changed his practice to comply with his obligation to review any papers filed in court over his signature, or that he has taken any steps to ensure that he and his law firm do not file motions or legal memorandum citing nonexistent case law in the future.This omission is surprising.And troubling.“Since Attorney Morgan’s failure to comply with basic ethical requirements in the Wyoming litigation is so recent, and Morgan has made no showing that he has learned from his mistakes in that case, the Court is not convinced that Morgan should be granted the privilege of appearing pro hac vice in the Massachusetts Superior Court.… “The Court’s concerns about Morgan’s recent misconduct in Federal court are heightened by his demonstrated disregard for the Massachusetts statute and SJC rule that govern requests for permission to appear pro hac vice in Massachusetts courts.“First, rather than have a member of the Massachusetts bar file a motion asking the court to give Attorney Morgan permission to appear in this case pro hac vice, as expressly required by SJC Rule 3:15, §2, Morgan filed the motion himself.… “Section 46A of G.L.221 provides that no one other than a member in good standing of the Massachusetts bar ‘shall practice law’ in Massachusetts.An exception is made for members in good standing of the bar of another State who has received ‘permission of the court’ to appear pro hac vice.“Morgan falls into neither category, but nonetheless decided to practice law in Massachusetts by filing this motion.Since Morgan is not a member of the Massachusetts bar and has not been granted permission to appear in this case pro hac vice, he violated §46A and Rule 3:15 by filing this motion on his own behalf.“Morgan’s decision to flout Massachusetts law in this manner is not a minor technical violation.… “Second, Attorney Morgan did not pay the correct pro hac vice registration fee to the Board of Bar Overseers (the ‘BBO’), and thereby committed a second violation of SJC Rule 3:15.… “… If Morgan had taken a moment to review Rule 3:15, he would have immediately seen that he was required to pay a $355 fee, not a $100 fee.Since Morgan did not certify or provide evidence that he paid the $355 fee before seeking permission to appear in the Massachusetts Superior Court, he failed to comply with the simple and clear requirements of SJC Rule 3:15.“In sum, these further transgressions suggest that Morgan has not learned from the mistakes that he made in the Federal case in Wyoming, and that at least for now he cannot be trusted to comply with Massachusetts law and procedural rules.They are a further reason why the Court is exercising its discretion to deny Morgan’s pro hac vice motion.… “After carefully considered the serious nature of Attorney T.Michael Morgan’s recent ethical violations while practicing before the United States District Court for the District of Wyoming, as well as his failure to comply with Massachusetts law in connection with his own pro hac vice motion in this case, the Court exercises its discretion to deny Attorney Morgan’s motion seeking permission to appear in this action pro hac vice pursuant to G.L.c.221, §46A.” Wilder, et al.President & Fellows of Harvard College, et al.(Lawyers Weekly No.09-044-26) (6 pages) (Salinger, J.) (Suffolk Superior Court) (Docket No.2384CV01461-BLS2) (May 18, 2026).Click here to read the full text of the opinion.