AI output retained as evidence, including errors. It is not an adopted legal opinion. Line numbers identify logical transcript lines, not original screen or court pages.
Prompt
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.
L006Short answer: no. In the one Utah state appellate decision on point, that exact explanation was offered and the court sanctioned the signing lawyer anyway. The explanation helped reduce the penalty. It did not avoid it.
L014¶5: “Petitioner’s counsel explained that the Petition had been prepared by an unlicensed law clerk, employed by their law firm, who used ChatGPT in the drafting of the Petition.” Also at ¶5: “Petitioner’s counsel were not aware that the law clerk was using ChatGPT in the preparation of their firm’s legal work”.
L028¶10: “And the signature of Mr. Bednar on the Petition served to “certif[y] that to the best of [his] knowledge formed after an inquiry reasonable under the circumstances,” the “legal contentions are warranted by existing law.”
L042No Rule 3.3 finding. In n.4 (attached to ¶10), the court found that counsel made a false statement of law, but “we find that their conduct fell short of the level of intent required by the rule.” Rule 3.3 requires that the false statement be made knowingly or recklessly.
L046Lighter sanctions. The court separated these facts from Mata v. Avianca, where counsel kept insisting the fake cases were real. ¶13: “Petitioner’s counsel’s conduct has not been similarly egregious, and they have accepted responsibility for their misrepresentations to this court.”
L057Practical read: Disclosing the clerk’s role early and fully is good mitigation. It is not a defense. In Garner, the court specifically noted that the firm had no AI policy, and the signer never checked the citations.
L071I found no Utah Supreme Court decision on this issue.
L072I found no published Utah trial-court ruling. Unpublished district court orders may exist, but I couldn’t reach them.
L073One tracker claims 22 Utah AI-hallucination decisions. I couldn’t verify that number, and many are probably federal (D. Utah), which falls outside your scope.
L074I don’t have P.3d page pinpoints for Garner. The paragraph pinpoints above follow Utah’s public-domain citation format.