US District Court, Northern District of Alabama, Northeastern Division (Judge Harold D. Mooty III)

Garry Chapman v. City of Priceville, et al., No. 5:26-cv-84-HDM (2026 WL 2350902)

Sanctioned · 12 August 2026

SectorLegal

CountryUnited States

Document typeResponse brief in opposition to a motion to dismiss, plus a 179-page amended complaint

ConsequenceSanctioned

What was fabricated

AI USE IS THE COURT'S INFERENCE, NOT AN ADMISSION — SEE BELOW. The filings contained 2 cases that do not exist (Williams v. City of Anniston; City of Prichard v. Kelley); 7 quotations attributed to real cases that do not contain the quoted material (Speaker, St. George, Stimpson, Griffin Industries, Personnel Bd. of Jefferson Cnty. v. Bailey, Tumey v. Ohio, Connick v. Thompson); and 2 further statements unsupported by the authority cited, one of which misrepresented Ala. Code § 11-47-190. A further false citation appeared in the 179-page amended complaint. ON THE AI ATTRIBUTION: the order carries an Editor's Note describing “unverified citations, likely generated by AI tools,” and footnote 2 states it “appears likely from the nature of the misrepresentations that the filings at issue were generated by artificial intelligence.” No party confirmed AI use. Counsel's own sworn account was different: that his client — who has no law degree — drafted both documents acting “in the capacity of paralegal,” and that citations were transcribed from Google Scholar, JD Supra and Lexology secondary discussions “without retrieving and reading the underlying opinions.” Counsel never pulled or read any cited case before signing and filing. The court treated the two as equivalent: “This is no different than submitting AI-generated work product to the court without thoroughly checking it.”

What happened as a result

Order of 12 August 2026, following a sua sponte show-cause order of 9 July and a hearing on 6 August. Attorney Scott Thomas Morro PUBLICLY REPRIMANDED under Fed. R. Civ. P. 11. He was ordered to serve a copy of the order on opposing counsel and the presiding judge in every pending state or federal case in which he is counsel of record, and on his client, by 4:00 p.m. on 24 August 2026, and to certify compliance within 24 hours. The Clerk was directed to submit the order for publication in the Federal Supplement. The court expressly declined — this time — to fine him, disqualify him, suspend him from the district or refer him to the Alabama State Bar, warning that all four remain on the table.

Sources

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