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.

Copilot said:

I found one Utah state-court decision (2023 through Nov. 4, 2026) that directly addresses your question: Garner v. Kadince, decided by the Utah Court of Appeals in 2025. I did not find any other Utah state appellate decision in that period addressing whether an attorney can avoid sanctions by claiming a law clerk used ChatGPT without the attorney's knowledge. Accordingly, I will not speculate beyond that case.
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Short answer

No. In Garner, the attorney did not avoid sanctions by explaining that an unlicensed law clerk used ChatGPT without his knowledge. The court imposed sanctions anyway because the attorney signed and filed the document without independently verifying its contents.
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Case
Garner v. Kadince, 2025 UT App 80, No. 20250188-CA (Utah Ct. App. May 22, 2025)
The attorneys' explanation

The court summarized the explanation as follows:

“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. Mr. Durbano was not involved with the drafting of the Petition and Mr. Bednar did not independently check the accuracy of the Petition before signing and filing it with the court.” Id. ¶ 5.
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The court further stated:

“Petitioner’s counsel were not aware that the law clerk was using ChatGPT in the preparation of their firm’s legal work, and they acknowledged that the use of AI had not been previously addressed at their firm, either formally or informally.” Id. ¶ 5.
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The court's response

Despite that explanation, the court held:

“However, we emphasize that every attorney has an ongoing duty to review and ensure the accuracy of their court filings.” Id. ¶ 8.
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And:

“In the present case, Petitioner’s counsel fell short of their gatekeeping responsibilities as members of the Utah State Bar when they submitted a petition that contained fake precedent generated by ChatGPT.” Id. ¶ 8.
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The court also stressed:

“A fake opinion is not ‘existing law’ that can support a party’s legal contention.” Id. ¶ 10.
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And:

“Mr. Bednar admits that he failed to comply with rule 40.” Id. ¶ 10.
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Sanctions imposed

The court ultimately ruled:

“This court takes the submission of fake precedent seriously and finds that sanctions are warranted.” Id. ¶ 12.
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It then ordered sanctions, including:

“Therefore, we order the following sanctions: (1) Mr. Bednar shall pay the attorney fees of Respondents for the time spent responding to the Petition and attending the OSC hearing … (2) Petitioner’s counsel shall refund to Petitioner all fees charged and paid for the filing of the Petition or related thereto … and (3) Mr. Bednar shall pay $1,000 in the form of a donation to ‘and Justice for all’ … .” Id. ¶ 16.
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Conclusion

Based on the Utah state-court decisions I could find from 2023 through Nov. 4, 2026, the answer is no. In Garner v. Kadince, 2025 UT App 80, the attorney argued that an unlicensed law clerk used ChatGPT without the attorney's knowledge, but the Utah Court of Appeals nevertheless imposed sanctions because the attorney signed and filed the pleading without independently verifying the citations and accuracy of the filing.
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I did not find any Utah state appellate decision during the requested period holding that a lawyer avoided sanctions on the ground that a law clerk used ChatGPT without the lawyer's knowledge.
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References
Check whether Garner was later modified
Find related Utah Rule 11 decisions
Compare federal AI-sanctions cases