Docket entry 36, 12 August 2026 · source · PDF · 15 pages
Docket text. ORDER: For the reasons explained herein, the court ORDERS as follows: The court PUBLICLY REPRIMANDS Attorney Scott Thomas Morro. To effectuate his reprimand, the court ORDERS Attorney Scott Thomas Morro to provide a copy of this Order to his opposing counsel and the presiding judge in every pending state or federal case in which he is counsel of record,4 as well as to Plaintiff Garry Chapman. Attorney Scott Thomas Morro must comply with this requirement by 4:00 p.m. on August 24, 2026, and must certify to the court within twenty-four hours of that deadline that the requirement has been met. To further effectuate the reprimand and deter similar misconduct by others, the Clerk of Court is DIRECTED to submit this Order for publication in the Federal Supplement. Signed by Judge Harold D Mooty, III on 8/12/2026. (LCB) (Entered: 08/12/2026)
DISTRICT COURT N.D. OF ALABAMA 2 brief, Defendants noted incorrect citations in Morro’s response brief, including two fabricated cases. (See Doc.
28 at 13–14 n.4). Nearly three weeks later, Morro filed a “Notice of Correction of Citations” withdrawing one of the fabricated case citations noted by Defendants and proffering another citation in its place. (See Doc.
31). The notice did not address the other fabricated case, nor did it address the as-yet- undiscovered errors at issue here. As the court explained in its Show-Cause Order, (doc.
(doc. 15 at 29) (containing both a nonexistent case (City of Prichard, see supra) and a misrepresentation of a real legal authority (Ala. Code § 11-47-190)).
The court also ordered him to “submit a sworn declaration that provides a thorough explanation for how any disputed filing, including the response brief, was generated. ” Id. at 5 (citation 5 omitted). Specifically, he was ordered to “explain precisely how the allegedly fabricated citations, quotations, and other representations were generated.” Id. Morro filed his response on July 15, 2026.
2025). This court has stated, Even in cases where lawyers who cite AI hallucinations accept responsibility and apologize profusely, much damage is done . The court spends time reviewing materials, holding hearings, deliberating 7 about sanctions, and explaining its ruling; the substance of the case is delayed; and public confidence about the trustworthiness of legal proceedings may be diminished.
False Statements of Law and Conclusions as to Morro 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.
11(b)(2), (c)(1). Morro presented to the court numerous citations, purported quotations, and representations that either do not exist or are unsupported by the cited law. See supra.