You said:
Can a Utah lawyer avoid sanctions for fabricated citations by explaining that a law clerk used ChatGPT without the lawyer's knowledge?

Limit this to Utah state court decisions from 2023 to November 4, 2026. For each case you cite, give the full citation and quote the sentence that supports the point, with its pinpoint. If you can't find a case that supports it, say so instead of guessing.
ChatGPT said:

I cannot establish that a Utah lawyer can avoid sanctions by claiming that a law clerk used ChatGPT without the lawyer's knowledge.

Within your specified scope, Utah state court decisions issued from January 1, 2023, through November 4, 2026, I cannot identify a verified decision that addresses this precise defense.

Because live legal research is unavailable in this session, I cannot reliably determine whether such a decision exists. I therefore cannot provide a verified full citation, supporting quotation, or pinpoint.

What can be said without inventing authority

The distinction is between who generated the fabricated citations and who was responsible for the filing.

A lawyer's lack of knowledge might be relevant to the court's assessment of culpability or an appropriate sanction. But it does not, by itself, establish that the lawyer is exempt from responsibility for a filing submitted under the lawyer's name.

That is a general legal distinction, not a holding I have verified from a Utah state court decision within your date range.

Conclusion

No qualifying Utah state court decision has been verified that supports the proposed defense.

That is not the same as establishing that no such case exists, or that Utah courts have categorically rejected the defense.

I would not cite a case, attribute a quotation to a Utah court, or claim a categorical Utah rule without checking the actual judicial opinion. Fabricating authority to answer a question about fabricated authority would be a particularly efficient way to demonstrate the problem.

ChatGPT can make mistakes. Check important info.
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