Claude responded: Short answer: no. Searched the web, read 2 pages  Searched the web, read 2 pages Short 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. The controlling case Garner v. Kadince, Inc., 2025 UT App 80, 571 P.3d 812 (per curiam), filed May 22, 2025. The facts match your question. Counsel told the court a non-lawyer clerk had drafted the petition with ChatGPT and they hadn’t known: ¶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”. justia  justia  The court held the duty belongs to the attorney and can’t be handed off: ¶8: “However, we emphasize that every attorney has an ongoing duty to review and ensure the accuracy of their court filings.” justia  The legal basis is the signature, not who did the drafting: ¶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.” justia  Apology and acceptance of responsibility did not prevent sanctions: ¶12: “This court takes the submission of fake precedent seriously and finds that sanctions are warranted.” justia  ¶14: “However, regardless of Petitioner’s counsel’s contrition, harm was done as a result of their acts.” justia  What the explanation did buy No 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. justia  Lighter 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.” justia  Who paid. The sanctions under ¶16 were: Opposing counsel’s fees and the $1,000 donation, imposed on Bednar, who signed the petition. A refund of the client’s fees, imposed on both attorneys. Durbano did not draft or sign the petition, but he still shared the refund obligation. Practical 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. What I checked and excluded Prisbrey v. Prisbrey, 2026 UT App 39 (Mar. 19, 2026) involved bad citations but doesn’t support the point. The court found that some citations “appear to be made out of whole cloth” (n.6). That is the only quote I’m taking from this opinion. s3  It made no AI finding, no clerk was involved, and it imposed no sanction, only criticism in a footnote. It’s useful only to show that the Court of Appeals checks citations closely. Gaps: I found no Utah Supreme Court decision on this issue. I found no published Utah trial-court ruling. Unpublished district court orders may exist, but I couldn’t reach them. One 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. I don’t have P.3d page pinpoints for Garner. The paragraph pinpoints above follow Utah’s public-domain citation format. Not legal advice. Pull the Garner opinion directly before citing it in a filing.  Create a doc      1 minute ago