The Initial Report · Supplemental · No. 02
Wilder v. Harvard College
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.

 
Source Record

1. Sources: MassCourts docket sheet for Wilder, 2384CV01461|May 18 order denying Morgan pro hac vice The docket sheet identifies the Wilder caption, case number, court record, and May 18 decision-and-order entry. The order is the core source for the PHV denial reasoning.

2. Sources: May 18 order denying Morgan pro hac vice|Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. 2025) The order discusses Morgan's District of Wyoming sanctions, cites Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. Feb. 24, 2025), and links the prior AI-citation sanctions record to the Massachusetts PHV decision.

3. Sources: Morgan's May 12 PHV motion|May 18 order denying Morgan pro hac vice The professional-liability framing is a limited inference from those records: a prior AI-citation sanction appears in a later admission decision.

4. Sources: MassCourts docket sheet for Wilder, 2384CV01461|Pennock's May 6 PHV motion

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.

6. Sources: MassCourts docket sheet for Wilder, 2384CV01461|Morgan's May 12 PHV motion|May 18 order denying Morgan pro hac vice Morgan's motion is used for the fact of his PHV request; the May 18 order supplies the court's description of Morgan and the denial reasoning.

7. Sources: May 18 order denying Morgan pro hac vice|MassCourts docket sheet for Wilder, 2384CV01461 The docket sheet records that the court considered both the serious nature of Morgan's recent ethical violations and his failure to comply with Massachusetts law in connection with his own PHV motion.
 
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