On Wednesday, April 30, 2025, the Massachusetts Board of Bar Overseers issued a public reprimand to Attorney Steven J. Marullo for professional misconduct related to inaccurate legal filings. The decision followed a stipulation between Marullo and Bar Counsel, accepted by the Board on April 14, 2025, to resolve the matter without a hearing.
The case is entitled “Bar Counsel v. Steven J. Marullo,” with case no. 2025-2.
Marullo, representing the estate’s representative in a wrongful death lawsuit filed in Norfolk Superior Court, faced issues stemming from motions to dismiss filed by four defendants between March and July 2023. His associate, aided by interns, prepared opposition filings Marullo signed and submitted. Unbeknownst to Marullo, the associate used an artificial intelligence tool for legal research, resulting in multiple erroneous citations, including four nonexistent cases, fabricated quotations, and misrepresentations of legal propositions and statutes.
During a November 1, 2023, court hearing, the presiding judge questioned Marullo about three nonexistent cases in his filings. Unable to explain, Marullo later submitted a written disclosure, revealing his office’s reliance on AI for the flawed research. A subsequent sanctions hearing on December 7, 2023, highlighted additional errors, including a fourth fictitious case and a misstated case proposition. Marullo admitted he had not verified the citations.
On December 14, 2023, Marullo filed amended oppositions to correct the errors, but some inaccuracies persisted. On February 12, 2024, the Norfolk Superior Court judge ruled that Marullo’s submissions violated Massachusetts Rules of Civil Procedure 11 and 7, imposing a $2,000 sanction for submitting false and misleading citations.
The Board found Marullo’s failure to verify citations and lack of oversight policies violated Massachusetts Rules of Professional Conduct 1.1 (competence), 1.3 (diligence), 5.1(a) and (b) (supervisory responsibilities), 5.3(a) and (b) (non-lawyer supervision), and 8.4(d) (conduct prejudicial to justice).
The case is the first in Massachusetts to involve AI misuse in legal practice. No mitigating factors were cited, and the Board imposed the public reprimand as stipulated.
The Disposition states:
“Whereupon, pursuant to Supreme Judicial Court Rule 4:01, Section 8(3), and the Rules of the Board of Bar Overseers, Section 3.56, it is ORDERED AND ADJUDGED that Steven J. Marullo be and hereby is PUBLICLY REPRIMANDED.”
According to Martindale.com, Mr. Marullo acquired his law license in Massachusetts in 1975.
A copy of the original filing can be found here.
