{ "recordId": "CJ-TR-20261104", "version": "1.3", "asOf": "2026-11-04", "completedAt": "2026-11-04T14:47:03.163015+00:00", "scope": "Presentation, speaker notes, numbered memorandum and contextual cases in the model-response exhibits; no blanket clearance of every citation inside full attached court opinions or corpus snapshots.", "method": "Public-source current-treatment review as of November 4, 2026: exact case/citation and docket searches with appeal, rehearing, certiorari, vacatur, reversal and reconsideration terms; court-authored documents and accessible official indexes checked. Positive citation distinguished from direct subsequent history. Research is complete for this presentation scope, with access and coverage limits recorded; no commercial citator clearance is claimed.", "cases": [ { "id": "CJ-CASE-01", "case": "Garner v. Kadince, Inc.", "citation": "2025 UT App 80, 571 P.3d 812 (May 22, 2025)", "role": "Main historical example and supplied-document task", "finding": "No adverse treatment located for the propositions used. Whiting, filed March 13, 2026, p.6, cites Garner at 815; the TOV/Kosel sanctions order, 355 Conn. 902, 905, quotes it. Cassata also lists it. These are later citations, not appellate affirmances of Garner.", "qualification": "Rule 40 sanctions; \u00b610 n.4 does not find the requisite intent under RPC 3.3. Available Utah certiorari reports May 2025\u2013April 2026 contain no name/docket match, but index coverage stops before the review date. Rehearing and later certiorari activity are not conclusively cleared.", "decision": "Retain the narrow historical example and paragraph pinpoints. Remove any suggestion that no later docket activity has been established.", "sources": [ "CJ-SRC-01", "CJ-CT-19", "CJ-CT-W01", "CJ-CT-13", "CJ-CT-20\u201325" ] }, { "id": "CJ-CASE-02", "case": "Mata v. Avianca, Inc.", "citation": "678 F. Supp. 3d 443; No. 22-cv-1461, ECF 54 (S.D.N.Y. June 22, 2023)", "role": "Main historical screenshots and sanctions example", "finding": "No adverse treatment located for the passages used. Whiting p.6 and Beus Gilbert ECF 385 p.2 cite Mata. ECF 55, issued the same day as ECF 54, dismisses the underlying claim as untimely under the Montreal Convention.", "qualification": "The sanctions analysis includes bad faith and continued reliance after warning. The merits dismissal is a separate order and must not be described as a sanction for the fabricated citations. The public docket mirror is dated and not a current PACER report.", "decision": "Retain the 2023 record, source screenshots and sanction qualification. Add the separate merits-order distinction.", "sources": [ "CJ-SRC-02", "CJ-LG-10", "CJ-CT-06", "CJ-CT-10", "CJ-CT-19" ] }, { "id": "CJ-CASE-03", "case": "Beus Gilbert PLLC v. Brigham Young University", "citation": "No. 2:12-cv-00970-TS, ECF 385 (D. Utah Sept. 9, 2026)", "role": "Recent Utah sanctions example in main slide and notes", "finding": "ECF 385 confirms the amounts, CLE requirement and named AI tools. ECF 386, dated September 14, 2026, confirms the arbitration award and denies the Robertson Trust\u2019s motion to vacate that award.", "qualification": "The motion to vacate in ECF 386 concerns the arbitration award, not vacatur of ECF 385 sanctions. No sanctions-vacatur order was located. Later compliance and any appeal are not certified by the public mirrors.", "decision": "Retain as a dated sanctions order; add the later merits-order distinction and link the saved ECF 385 directly.", "sources": [ "CJ-CT-06", "CJ-CT-07" ] }, { "id": "CJ-CASE-04", "case": "Lacey v. State Farm General Insurance Co.", "citation": "No. 2:24-cv-05205-FMO-MAA, ECF 119 (C.D. Cal.; signed May 5/filed May 6, 2025)", "role": "Contextual comparison in retained Claude A1, not a Utah answer", "finding": "ECF 119 is a special-master order. After settlement notice, ECF 146 dismissed without prejudice on July 24, 2025, allowing reopening within 60 days; ECF 148 dismissed with prejudice on September 18, 2025.", "qualification": "The dismissal order reviewed does not address or vacate ECF 119. Do not infer that settlement reverses the sanctions, and do not call the special master\u2019s order a district judge\u2019s or Utah court\u2019s holding. No complete post-settlement docket/citator clearance.", "decision": "Retain only as labeled contextual material; update the full case name, tribunal role and later dismissal history.", "sources": [ "CJ-SRC-03", "CJ-CT-08", "CJ-CT-09" ] }, { "id": "CJ-CASE-05", "case": "Prisbrey v. Prisbrey", "citation": "2026 UT App 39, 588 P.3d 329 (March 19, 2026)", "role": "Excluded AI-sanctions lead discussed in saved model responses", "finding": "Watson v. Prestwich, 2026 UT App 122, \u00b627 n.8 (Aug. 6, 2026), cites Prisbrey \u00b623 & n.6 on briefing and citation standards. No adverse treatment located for that limited point.", "qualification": "Prisbrey vacates a district-court divorce judgment and remands; that is its disposition, not later negative treatment of Prisbrey. Footnote 6 criticizes citations but does not find AI use. Available certiorari index coverage is incomplete after April 2026.", "decision": "Keep excluded as evidence of AI-caused sanctions. Replace the random document-host link with a court-opinion PDF mirror and add the reporter citation verified in Watson.", "sources": [ "CJ-CT-12", "CJ-CT-05" ] }, { "id": "CJ-CASE-06", "case": "Wadsworth v. Walmart Inc.", "citation": "348 F.R.D. 489; No. 2:23-cv-00118-KHR, ECF 181 (D. Wyo. Feb. 24, 2025)", "role": "Source-attribution context for Garner \u00b67 and the Gemini error", "finding": "The underlying ECF 181 sanctions order was retained. Whiting p.6 cites Wadsworth at 495; Garner \u00b67 attributes its quoted passage to Wadsworth rather than Mata.", "qualification": "No adverse treatment located for the narrow attribution point. This is not an independent claim of current binding Utah law, nor a complete review of the underlying products-liability litigation.", "decision": "Retain as contextual source attribution; supply the exact original order.", "sources": [ "CJ-CT-11", "CJ-CT-19", "CJ-SRC-01" ] }, { "id": "CJ-CASE-07", "case": "TOV Realty, LLC v. Suarez / Kosel Equity, LLC v. MacGregor", "citation": "355 Conn. 902, 905; SC 21183/21184 (sanctions order dated July 31, 2026; mirror release metadata Aug. 4)", "role": "Later judicial citation to Garner, named in speaker notes", "finding": "Court-authored text at 355 Conn. 905 quotes Garner at 815 about harm from fabricated citations. The order is ancillary to the earlier merits opinions, not appellate review of Garner.", "qualification": "The official PDF request reset; court text was inspected through the web-tool mirror. No adverse treatment located in targeted searches, but no complete subsequent docket/citator report. Distinguish the July 31 order date from the August 4 mirror release metadata.", "decision": "Retain only the verified later-citation proposition, with full citation and date distinction in the review record.", "sources": [ "CJ-CT-W01" ] }, { "id": "CJ-CASE-08", "case": "Whiting v. City of Athens, Tennessee", "citation": "Nos. 24-5918/5919/25-5424, filed March 13, 2026; sanctions opinion, p.6 (6th Cir.)", "role": "Later judicial citation to Garner, Mata and Wadsworth", "finding": "The filed court PDF at p.6 quotes Mata and string-cites Garner and Wadsworth in discussing fabricated authorities. No adverse treatment located in targeted searches.", "qualification": "The separately issued merits opinion is not this sanctions opinion. Do not infer that AI generated the false citations or name a tool from this citation alone. The court-host bare domain did not resolve; the filed PDF was retained from a public mirror.", "decision": "Retain the exact p.6 citation, without a broader AI-attribution or finality claim.", "sources": [ "CJ-CT-19" ] } ], "nonAuthorities": [ { "name": "Varghese v. China Southern Airlines Co., Ltd., 925 F.3d 1339", "status": "Fabricated case used as a labeled teaching example, documented in Mata ECF 54. Not cited as authority." }, { "name": "Royer v. Nelson, 2007 UT App 74, 156 P.3d 789", "status": "Fabricated case identified by Garner \u00b62. Preserved in verbatim model exhibits, not adopted as authority." }, { "name": "Bingel v. New York County District Attorney", "status": "Unverified case name in Qwen P3 only. No matching authority located in targeted public searches. No fabrication finding asserted; excluded from relied-on authorities." }, { "name": "Other cases embedded in complete court documents, graph corpus snapshots or verbatim exhibits", "status": "Attachment presence does not adopt every embedded citation as presentation authority. No raw exhibit or original response was changed." } ], "accessLimits": [ "CourtListener anonymous search returned 401; Mata docket returned 403; TOV opinion returned empty HTTP 202. No login, paid search or bypass attempted.", "Justia docket pages were readable through the web research tool but direct requests returned 403. Mirror last-retrieved dates are dated coverage, not current PACER certification.", "The official Utah disposition index linked reports through March\u2013April 2026; its granted-order index listed entries through June 11, 2026 at retrieval. Neither establishes coverage to November 4.", "The official Connecticut PDF request reset. Its court-authored text was read through a public mirror via the web research tool; the bare mirror URL returned 404. Retained web-tool receipt is private review evidence.", "The bare Sixth Circuit opinion host did not resolve. The court-authored filed opinion was retained from a public PDF mirror, with its docket/document header.", "No negative search result is represented as a complete citator report, docket certification, affirmance or finality finding." ], "conclusion": "Public-source review complete for the presentation scope. No adverse disposition located that changes the narrow historical propositions used. This is not a commercial citator clearance or a representation that every appeal, rehearing, mandate, compliance filing or sealed docket event was retrieved." }