# Utah State Court Sanctions for AI-Generated Citations: The "Clerk Used ChatGPT" Defense ## Short answer I cannot identify a Utah **state** court decision from 2023 through November 4, 2026 in which a court specifically ruled on whether a signing attorney can avoid sanctions for fabricated citations by asserting that a law clerk used ChatGPT without the attorney's knowledge. Rather than guess at a docket number or fabricate a pinpoint, I will say plainly: **I do not have a verified Utah state-court opinion on this exact fact pattern to cite.** Below is what I *can* responsibly say about the governing framework, followed by a candid note on what I could not confirm. --- ## Governing Utah authorities I am confident exist (rules, not cases) - **Utah Rules of Professional Conduct, Rule 3.1** (meritorious claims/arguments) and **Rule 4.1** (truthfulness to a third party, i.e., the court) place the duty on the *signing attorney* to verify the legal authority cited. The rules do not contain a "my paralegal did it" carve-out. - **Utah Rules of Civil Procedure, Rule 11** (and its criminal/probation counterparts) impose a personal certification duty on the attorney who signs or files the document. - **Utah Supreme Court, Rule 8-402 et seq.** (attorney discipline) makes the attorney individually accountable for violations of the RPC. These are rule provisions, not court opinions, so I am not citing them as "cases." They matter because any Utah panel addressing your hypothetical would anchor its analysis in them. --- ## Why I am stopping here instead of providing a case cite 1. **The pool is very narrow.** The question requires (a) a *Utah state* (not federal) decision, (b) issued between January 1, 2023 and November 4, 2026, (c) addressing *AI-fabricated* citations specifically (not generic "phantom case" sanctions), and (d) reaching the *clerk-without-knowledge* defense. I am not aware of a published Utah Court of Appeals or Utah Supreme Court opinion that hits all four points. 2. **My training data has a knowledge cutoff**, and even within that window I cannot recall a Utah state opinion that names ChatGPT or a generative-AI tool and rules on the attorney's vicarious-responsibility defense in the sanctions context. Federal district courts in Utah (e.g., the District of Utah) have touched on AI citations, but those are *federal* courts, not Utah state courts, and you asked me to exclude them. 3. **Fabrication risk.** Inventing a plausible-sounding citation like *In re Sanctions, 2024 UT App 12, 534 P.3d 412* and then attributing a quoted sentence to it would be exactly the kind of hallucinated authority the question is about. I will not do that. --- ## What I would look for if I had live access to a Utah legal database To confirm or disprove the existence of such a case, I would search: - **Utah Supreme Court and Utah Court of Appeals opinions (Westlaw / Utah Legal Services / UtahBar.org)** with terms: "ChatGPT" OR "generative AI" OR "AI-generated" AND "sanction" OR "Rule 11" AND "paralegal" OR "clerk" OR "staff," limited to 2023–2026. - **Utah Bar Association disciplinary decisions** published in the *Utah Bar Journal* or the discipline docket, 2023–2026. - **Utah Supreme Court orders** (many sanctions orders are issued as unreported orders rather than published opinions) via the court's public docket. - **Utah Court of Appeals Rule 11 memoranda** (some are non-precedential but still "state court decisions"). If a hit exists, the controlling sentence would almost certainly reiterate the principle already embedded in RPC Rule 3.1 and RPC Rule 4.1: the signing attorney bears personal responsibility for the accuracy of every citation, and delegation to staff does not transfer that duty. I can predict the *direction* of the holding with high confidence, but I will not dress that prediction up as a quotation with a fabricated pinpoint. --- ## Bottom line To the best of my verified knowledge, **no Utah state court decision in the 2023–November 4, 2026 window that I can confidently cite addresses the "my clerk used ChatGPT and I didn't know" defense to sanctions for fabricated citations.** The general rules (RPC 3.1, 4.1, 8.4; CRP Rule 11) strongly suggest the defense would *not* excuse the attorney, but I will not attribute that conclusion to a specific case I have not actually confirmed. If you need a citable authority for a brief or motion, I'd recommend pulling the Utah Bar's published discipline decisions and the Court of Appeals' Rule 11 memos directly, or contacting the Utah State Bar's discipline division for any pending or recently closed matters on point.