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Courts on AI / Fabricated or misquoted citations

Chapman v. City of Priceville

United States District Court for the Northern District of Alabama · Federal district courts · AL · · 2026 WL 2350902 · No. 5:26-cv-84-HDM · order

The Northern District of Alabama sanctions Scott Morro for false citations, quotations, and legal representations in Chapman v. City of Priceville. The court treats client-drafted filings submitted without verification like unchecked AI work, publicly reprimands Morro, orders notice in pending cases, and directs publication.

Disposition
The court publicly reprimanded attorney Scott Morro and ordered notice to opposing counsel and presiding judges in pending cases.
Recorded conduct
Plaintiff’s counsel filed nonexistent cases and false quotations/propositions drafted by his client without reading and verifying the cited authorities. — outcome: sanctions; actor: lawyer
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

The court finds, based upon its own careful review and Morro's admission, (doc. 34 at 1–2), that the purported citations, quotations, and representations of law in the filings at issue were fabricated. Accordingly, by citing nonexistent cases and attributing nonexistent quotations and propositions of law to actual authorities, Morro made false statements of law. Morro admits that his nonlawyer client drafted the filings at issue and that Morro submitted the filings to the court without ensuring that the assertions within were legally correct. Transcript of 8/6/2026 Show Cause Hearing at 5–10. This is no different than submitting AI-generated work product to the court without thoroughly checking it. Morro signed the filings, and he is responsible for them. ... Morro presented to the court numerous citations, purported quotations, and representations that either do not exist or are unsupported by the cited law. ... Accordingly, the court will not, in this instance, refer this matter to the Alabama State Bar, order a monetary fine, disqualify Attorney Morro from this case, or suspend him from practice in the Northern District of Alabama, though he is WARNED that each of these options is on the table should he commit a similar infraction in the future. ... The court PUBLICLY REPRIMANDS Attorney Scott Thomas Morro.

Authorities cited in the passage: Fed. R. Civ. P. 11 · Kaplan v. DaimlerChrysler, A.G., 331 F.3d 1251 (11th Cir. 2003) · Miller v. Regions Bank, 2026 WL 1430381 (N.D. Ala. May 21, 2026) · Johnson v. Dunn, 792 F. Supp. 3d 1241 (N.D. Ala. 2025)

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