Chapman v. City of Priceville

What sanction did the court impose?

The court found, "based upon its own careful review and Morro's admission," that the citations, quotations and representations of law were fabricated and that Morro made false statements of law. It held that submitting a non-lawyer client's draft without checking it "is no different than submitting AI-generated work product to the court without thoroughly checking it," and that his conduct was "akin to contempt" under Rule 11. It treated his notice of correction, filed only after opposing counsel raised two of the cases, as equivalent to a correction after a show-cause order, and credited his apology and acceptance of responsibility. The court publicly reprimanded Morro, ordered him to provide a copy of the order to opposing counsel and the presiding judge in every pending state or federal case in which he is counsel of record and to his client by August 24, 2026 and to certify compliance, and directed the Clerk to submit the order for publication in the Federal Supplement. It declined to refer him to the Alabama State Bar, fine him, disqualify him or suspend him, but warned that each option remains available for a similar infraction.

Why does Chapman v. City of Priceville matter for law firms using AI?

Chapman extends the AI-hallucination sanctions framework to a brief a lawyer did not draft himself. Morro’s explanation was that his client, who has no law degree, wrote the response brief and the amended complaint, and that Morro “read,” “tweak[ed],” and “tr[ied] to make sure” the response brief was correct without pulling the cited cases. The court noted in a footnote that Morro’s written response did not disclose Chapman’s authorship of the 179-page amended complaint, which also contained a false citation, and called that omission “notable” because the show-cause order required a “thorough explanation” of how “any disputed filing” was generated. Judge Mooty treated that as no defense: “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.” The footnote to that passage adds that AI generation “appears likely from the nature of the misrepresentations,” but the court did not rest the sanction on AI use, and it noted that Rule 11 and the professional conduct rules did not reach the client, who neither signed the filing nor is an officer of the court.

The order is explicit about timing and self-correction. The court stated that had Morro filed a notice of correction “on his own initiative and without any assurance that the court would have caught the misrepresentations at all,” he “would not have been sanctioned for the initial false citations,” but “once the court or another party forces the issue, that ship has sailed.” Because his notice came after opposing counsel flagged two cases, and fixed only one, the court treated it like a correction made after a show-cause order.

The sanction reflects the court’s stated practice of reserving harsher measures for “dishonesty in attempting to cover up” wrongdoing. The court recognized Morro’s apology and acceptance of responsibility and did not refer him to the Alabama State Bar, fine him, disqualify him or suspend him, warning that each option remains available. A footnote adds that failing to comply with the notification requirements is “a sure way to get one’s case referred to the Alabama State Bar, an outcome that Morro has thus far avoided.” The reprimand travels: he must send the order to every presiding judge and opposing counsel in his pending cases, and the Clerk was directed to submit it for publication. Firms documenting compliance may wish to consider that, in this court’s view, the verification duty attaches to the signature regardless of whether a person, a client or an AI tool produced the draft.