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:
Short answer

I cannot identify a verified Utah state court decision issued between January 1, 2023, and November 4, 2026, holding that an attorney can avoid sanctions for fabricated citations by claiming that a law clerk used ChatGPT without the attorney's knowledge.

I also cannot establish that Utah courts have categorically rejected that defense.

Web search is unavailable in this session, so I cannot conduct the case-law search necessary to verify either proposition.

Applicable legal principles

Two Utah authorities are particularly relevant:

Utah Rule of Civil Procedure 11(b) requires an attorney presenting a pleading, written motion, or other paper to certify that its legal contentions are warranted by existing law or a nonfrivolous argument for changing the law. Rule 11(c) provides for sanctions when the rule is violated, subject to its procedural requirements.

Utah Rule of Professional Conduct 5.3 addresses lawyers' responsibilities concerning nonlawyer assistants. Depending on the circumstances, a lawyer may bear responsibility for a nonlawyer assistant's conduct, particularly when the lawyer directs, ratifies, or fails to take appropriate corrective action concerning misconduct.

These rules suggest that lack of personal knowledge of a law clerk's ChatGPT use would not necessarily relieve the supervising attorney of responsibility. But that is an inference from the rules, not a verified holding from a Utah appellate or trial court decision within your specified period.

Case-law findings

Required finding

	

Result




Utah state court decisions, 2023–November 4, 2026

	

No qualifying decision verified




Decision addressing fabricated AI citations attributed to a law clerk

	

None verified




Decision accepting lack of attorney knowledge as a sanctions defense

	

None verified




Decision rejecting that defense

	

None verified




Full case citations, supporting quotations, and pinpoints

	

None provided because no qualifying opinion was verified

Conclusion

The proposed defense is not established by any Utah state court decision I can verify. A lawyer's assertion that a clerk independently used ChatGPT may be relevant to culpability or the appropriate sanction, but it should not be treated as an automatic defense.

A definitive answer requires checking Utah appellate opinions and available state trial court sanctions orders through November 4, 2026.

I will not manufacture a case citation, quotation, or pinpoint to fill that evidentiary gap. That would be a particularly unfortunate way to answer a question about fabricated legal citations.

ChatGPT can make mistakes. Check important info.
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