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Incident Tracker / United States (federal)

Chapman v. City of Priceville, No. 5:26-cv-84-HDM (N.D. Ala.)

·US District Court for the Northern District of Alabama·US-FEDSanctions

The US District Court for the Northern District of Alabama, the same district that sanctioned Butler Snow in Johnson v. Dunn, publicly reprimanded civil-rights plaintiff's lawyer Scott Morro for a brief containing two fabricated cases and seven invented quotations. He must serve the order on every judge before whom he appears, and the court directed publication as a warning.

Court
US District Court for the Northern District of Alabama
Date
2026-08-12
Who used the AI
Lawyer
AI tool
Not identified in the record
Conduct
Attorney Scott Thomas Morro's opposition brief cited two fabricated cases, attributed quotations to seven real cases that do not contain them, and misrepresented the law. His subsequent Notice of Correction fixed only one item. After a show-cause hearing the court publicly reprimanded him, declined in this instance to refer him to the Alabama State Bar, fine, disqualify or suspend him, and warned that each of those options is on the table for any repeat.
Outcome
Sanctions
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-03

What was fabricated or misused

  • Williams v. City of Anniston, 396 So. 2d 707, 708 (Ala. Civ. App. 1981); case does not appear to exist
  • City of Prichard v. Kelley, 292 Ala. 385, 295 So. 2d 414 (1974); case does not appear to exist
  • Speaker v. U.S. Dep’t of Health & Human Servs., 623 F.3d 1371, 1380 (11th Cir. 2010); quotation beginning "whether a plaintiff will ultimately prevail" not in the case
  • St. George v. Pinellas County, 285 F.3d 1334, 1337 (11th Cir. 2002); quotation beginning "only when the complaint shows on its face" not in the case
  • Stimpson v. City of Tuscaloosa, 186 F.3d 1328, 1332 (11th Cir. 1999); quotation beginning "When the biased recommender" not in the case
  • Griffin Indus., Inc. v. Irvin, 496 F.3d 1189, 1204–06 (11th Cir. 2007); quotation about the "similarly situated" requirement not in the case
  • Personnel Bd. of Jefferson Cnty. v. Bailey, 475 So. 2d 863, 866 (Ala. Civ. App. 1985); quotation beginning "may not retry the case" not in the case
  • Tumey v. Ohio, 273 U.S. 510, 523 (1927); quotation beginning "[N]o man is permitted" not in the case
  • Connick v. Thompson, 563 U.S. 51, 60–61 (2011); quotation beginning "official municipal policy of some kind" not in the case
  • Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274, 287 (1977); cited for an unsupported pleading-stage proposition about motive
  • Ala. Code § 11-47-190; misrepresented as supporting the statement that municipal contract immunity does not extend to a city's breach of its own written promise
  • Additional false citation in the 179-page Amended Complaint identified by counsel's review; the order did not name it

What the court said

“he cites two cases that do not appear to exist: Williams v. City of Anniston, 396 So. 2d 707, 708 (Ala. Civ. App. 1981), (doc. 15 at 18), and City of Prichard v. Kelley, 292 Ala. 385, 295 So. 2d 414 (1974), (doc. 15 at 29).”
US District Court for the Northern District of Alabama, p. 2
“This is no different than submitting AI-generated work product to the court without thoroughly checking it.”
US District Court for the Northern District of Alabama, p. 10
“Attorneys should not wait to take corrective action until they know whether they will get in trouble for failing to do so.”
US District Court for the Northern District of Alabama, p. 13
“The court PUBLICLY REPRIMANDS Attorney Scott Thomas Morro.”
US District Court for the Northern District of Alabama, p. 14

Timeline

  1. Defendants moved to dismiss Chapman's Amended Complaint.
  2. Morro filed the response brief containing fabricated cases and quotations.
  3. Court ordered Morro to show cause and explain how the filings were generated.
  4. Morro responded, withdrew the erroneous material and accepted responsibility.
  5. Court held a show-cause hearing about the filings.
  6. Court publicly reprimanded Morro and directed Federal Supplement publication.

Why this case matters

Chapman shows the Northern District of Alabama applying the Johnson v Dunn line outside a defence-side ChatGPT filing. The court treated a lawyer's signature on client-drafted work like submitting unchecked AI output because counsel did not read the cases. The sanction was narrower than Johnson: no bar referral, suspension, disqualification or fine. Instead, the order used public reprimand, service on every presiding judge in pending cases, and Federal Supplement publication. That distinction helps the tracker separate concealment or repeated false filings from late but complete responsibility.

Practice note

Do not let a client, paralegal or AI system supply legal authorities that go into a signed filing until counsel has opened each case and read the cited page. A correction must be complete and voluntary: withdraw every false case, quotation and proposition before an opponent or judge has to identify the rest.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Chapman v. City of Priceville, No. 5:26-cv-84-HDM (N.D. Ala.)”, safelegalai.com/tracker/chapman-v-city-of-priceville (accessed 2026-10-07). Data: CC BY 4.0.

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