Massachusetts — Steven J. Marullo: first Massachusetts AI disciplinary case
Steven J. Marullo — Massachusetts This was a particularly instructive case. Marullo represented an estate in a wrongful-death case. His associate and interns prepared opposition papers. The associate used AI for legal research. The…
Steven J. Marullo — Massachusetts
This was a particularly instructive case.
Marullo represented an estate in a wrongful-death case.
His associate and interns prepared opposition papers. The associate used AI for legal research.
The filings contained:
four nonexistent cases;
nonexistent quotations;
misrepresentations of what real cases held;
misstatements of statutory propositions.
Marullo signed the papers without verifying the authorities.
When the judge discovered the fabricated cases, Marullo eventually disclosed that AI had been used.
The Massachusetts Board of Bar Overseers imposed a public reprimand in April 2025.
The violations included:
Rule 1.1 — competence;
Rule 1.3 — diligence;
Rule 5.1 — supervision;
Rule 5.3 — supervision of nonlawyer assistance;
Rule 8.4(d) — conduct prejudicial to administration of justice.
The Massachusetts Board specifically described this as a matter of first impression involving misuse of AI.