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:

Based on my search of Utah state court decisions from January 1, 2023 through November 4, 2026, I found one Utah state appellate decision directly addressing this situation: Garner v. Kadince, 2025 UT App 80 (Utah Ct. App. May 22, 2025). I did not find any other Utah state appellate decision during that period holding that a lawyer can avoid sanctions by claiming a law clerk used ChatGPT without the lawyer's knowledge.
thelawlion

Short answer

No. In Garner v. Kadince, the attorneys explained that an unlicensed law clerk used ChatGPT without the attorneys' knowledge, but the Utah Court of Appeals nevertheless imposed sanctions because the signing attorney failed to verify the filing.
thelawlion

The case

Garner v. Kadince, 2025 UT App 80 (Utah Ct. App. May 22, 2025).
thelawlion

Facts showing the attorneys raised the law-clerk explanation

Paragraph 5 states:

“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. Bednar did not independently check the accuracy of the Petition before signing and filing it with the court. Petitioner’s counsel were not aware that the law clerk was using ChatGPT in the preparation of their firm’s legal work … .”¶ 5.
thelawlion

The court's statement of the attorney's duty

Paragraph 8 states:

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

The same paragraph continues:

“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.”¶ 8.
thelawlion

The court's holding that the rule was violated

Paragraph 10 states:

“Here, the Petition failed to comply with rule 40. A fake opinion is not ‘existing law’ that can support a party’s legal contention.”¶ 10.
thelawlion

The court further stated:

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

The sanction ruling

The opening paragraph of the opinion states:

“The court, having reviewed the filings and heard from the parties at the April 22, 2025 OSC hearing, finds that Petitioner’s counsel violated rule 40 of the Utah Rules of Appellate Procedure and imposes sanctions.”¶ 1.
thelawlion

And paragraph 12 states:

“Although the court appreciates Petitioner’s counsel’s acceptance of responsibility for their conduct, filing pleadings or other legal documents without taking the necessary care in their preparation is an abuse of the judicial system and subject to sanctions.”¶ 12.
thelawlion

Conclusion

I found no Utah state court decision from 2023-Nov. 4, 2026 holding that an attorney can avoid sanctions by explaining that a law clerk used ChatGPT without the attorney's knowledge. The Utah Court of Appeals' decision in Garner v. Kadince, 2025 UT App 80, points the other way: the court accepted that the law clerk used ChatGPT without the attorneys' knowledge, but still held that the attorneys had a duty to verify the filing and imposed sanctions.
thelawlion

References
Find the exact sanction imposed
Check for Utah Supreme Court cases
Compare with federal ChatGPT sanctions