Morgan v. Community Against Violence
U.S. District Court, District of New Mexico · D.N.M. · New Mexico bar guidance
Conduct
Pro se employment plaintiff cited 3+ fabricated cases including Doe v. United Airlines and EEOC v. Lockheed Martin across multiple filings.
Consequence
Three-stage escalation: Oct 23, 2023 Rule 11 warning; Jan 19, 2024 dismissal with prejudice; Feb 15, 2024 OSC re filing restrictions.
Lesson
Progressive sanctions: a single matter can produce warning, then dismissal, then filing restrictions over four months.
Verified May 15, 2026
- Citation
- Morgan v. Community Against Violence, No. 1:23-cv-00353-WPJ/JMR (D.N.M. Feb. 15, 2024) (Johnson, C.J.)
- Decided
- February 15, 2024
Summary
Sorche A. Morgan, a pro se plaintiff, filed an employment civil rights action on April 26, 2023 against her former employer Community Against Violence (a Taos, New Mexico nonprofit) and four individual employees. Throughout the litigation Morgan filed briefing containing fabricated citations, including "Doe v. United Airlines, Inc., 754 F.3d 576 (7th Cir. 2014)," whose reporter citation actually corresponds to Young v. Builders Steel Co.; "EEOC v. Lockheed Martin Corp., 116 F. Supp. 3d 734 (E.D. Pa. 2015)," whose reporter citation corresponds to Caldwell v. Bristol Myers Squibb; and "Las Cruces Sun-News v. City of Las Cruces (2003-NMCA-099)," which is actually State v. Foster. The case generated three relevant orders by Chief District Judge William P. Johnson: an October 23, 2023 order partially granting dismissal with a Rule 11 warning, a January 19, 2024 order dismissing the remaining claims with prejudice, and a February 15, 2024 order to show cause regarding filing restrictions and denying reconsideration.
- AI tool:
- ChatGPT (referenced in opinion footnote discussing legal-ethics implications of AI-authored motions)
What sanction did the court impose?
February 15, 2024 order: reconsideration motion denied; untimely motions stricken; Morgan ordered to show cause why she should not be restricted from future filings without attorney representation. The case had already been dismissed with prejudice on January 19, 2024 after Johnson found Morgan had continued to file briefing with fabricated citations notwithstanding the October 23, 2023 warning. The escalation across the three orders (warning leading to dismissal leading to a show-cause order on prospective filing restrictions) is one of the clearest reported examples of progressive AI-citation sanctions in a single matter.
Why does Morgan v. Community Against Violence matter for law firms using AI?
Morgan v. Community Against Violence is the longest-running D.N.M. AI-citation matter on record, generating three separate orders by Chief Judge William P. Johnson over a four-month span. The first order (October 23, 2023) issued the Rule 11 warning and identified specific fabricated citations by reporter mismatch; the second order (January 19, 2024) dismissed the remaining claims with prejudice when Morgan continued to file briefing with fabricated citations; the third order (February 15, 2024, the date catalogued here) denied reconsideration, struck untimely motions, and ordered Morgan to show cause why she should not be barred from future filings without attorney representation. The progression establishes a chambers template for graduated sanctions in pro se AI-citation cases that later D.N.M. orders (Tomlin, Lowrey, Maturin) reference. The matter is also the earliest of the catalogued D.N.M. AI orders, predating the formal “ChatGPT” footnote in many later orders. Cross-reference: Tomlin v. State of New Mexico (D.N.M. Sept. 30, 2025); Lowrey v. City of Rio Rancho (D.N.M. Nov. 5, 2025); Maturin v. T-Mobile USA, Inc. (D.N.M. Dec. 15, 2025).
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Document a chambers-aware litigation timeline for any matter against a pro se opposing party with prior Rule 11 warnings; the Morgan series shows that courts in this district will escalate from warning to dismissal to a show-cause order on prospective filing restrictions across a four-month window when AI conduct continues.
- When a pro se litigant has already received a Rule 11 warning in a prior order, point this out in subsequent briefing; the Morgan progression shows that the warning converts into a sanctions trigger if the conduct recurs.
- Consider seeking prospective filing restrictions (rather than dismissal alone) when an AI-citation pattern persists across multiple filings; the Morgan show-cause order is an early model for the procedural posture courts in the D.N.M. are willing to adopt before imposing the restriction.
Sources
Primary sources
Further reading
- Ropes & Gray (legal aggregator)
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.