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.

For the requested period, January 1, 2023, through November 4, 2026, I cannot identify a verified Utah state court decision that directly addresses this defense and provides the required quotation and pinpoint citation.

Web search is unavailable in this session, so I cannot conduct or verify an exhaustive review of Utah appellate and trial court decisions through November 4, 2026.

What can be said

The relevant legal distinction is between two questions:

Responsibility: Whether an attorney remains responsible for a court filing containing fabricated authorities when the fabrication originated with a law clerk.

Sanctions: Whether the attorney's lack of knowledge affects the availability, appropriateness, or severity of sanctions.

These are not necessarily the same question. A lawyer's responsibility for supervising work and verifying submissions does not automatically establish that a particular sanction is warranted.

Utah Rule of Civil Procedure 11 and the Utah Rules of Professional Conduct, particularly Rules 3.3, 5.1, and 5.3, provide relevant frameworks. But those rules alone do not establish how a Utah court has decided the precise factual scenario you've described.

Case authority

Requested authority

	

Verified finding




Utah state court decisions, 2023–November 4, 2026, addressing fabricated citations generated by ChatGPT

	

None verified




Decisions accepting an attorney's lack of knowledge of a clerk's ChatGPT use as a defense to sanctions

	

None verified




Decisions rejecting that defense

	

None verified




Verbatim supporting sentences with pinpoint citations

	

None available for verification

Conclusion

The proposed defense is not established by any Utah state court decision I can verify within your specified period.

That does not mean no such decision exists, nor does it mean the defense would necessarily fail. It means the requested case-law support has not been established.

I won't manufacture a citation to answer a question about fabricated citations. That would be a fairly spectacular failure of the assignment.

ChatGPT can make mistakes. Check important info.
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