Stone River Law – Criminal Defense Team

Garner v. Kadince, 2025 UT App 80: Utah Lawyers Sanctioned for Citing AI Hallucinations

HERE FOR YOU WHEN IT MATTERS.

The Utah Court of Appeals sent a clear message to the legal world: using AI doesnโ€™t excuse sloppy lawyering. In Garner v. Kadince, 2025 UT App 80, the court sanctioned two attorneys for filing a legal brief that cited fake cases generated by ChatGPT. One of the made-up cases, โ€œRoyer v. Nelson,โ€ didnโ€™t exist in any legal databaseโ€”only in the chatbotโ€™s imagination.

The attorneys admitted the mistake. They said the brief had been written by an unlicensed law clerk who used AI. One of them signed the document without checking the citations. Neither had policies in place to govern AI use in the firm.

The court wasnโ€™t amused.

Why This Matters

This case marks Utahโ€™s first disciplinary action over AI-generated โ€œhallucinationsโ€ in court filings. It wonโ€™t be the last. Courts across the country are starting to confront the risks of AI in the legal profession. The lesson is simple: AI can help lawyers work fasterโ€”but not if it makes them careless.

Judges and opposing counsel shouldnโ€™t have to verify whether a case an attorney cites actually exists. Thatโ€™s the attorney’s job. The integrity of the judicial system depends on the accuracy and honesty of legal filings. As AI becomes more integrated into legal practice, attorneys must ensure that technology enhances, rather than undermines, the pursuit of justice.

The Consequences

The Utah court imposed several penalties:

  • Reimbursement of opposing counsel’s fees.
  • A full refund to the Petitioner for any fees paid for the flawed petition.
  • A donation of $1,000 to the legal aid organization “and Justice for All”.

Similar incidents have occurred elsewhere, notably in Mata v. Avianca, where attorneys faced sanctions for submitting AI-generated briefs with fictitious citations.

The Bigger Picture

AI isnโ€™t going away. Tools like ChatGPT are becoming common in law offices, especially among junior staff. Used properly, AI can streamline research, draft basic documents, and flag issues. But the duty to verify the accuracy of legal citations and arguments remains paramount.

This case is a warning. Law firms need clear policies. Attorneys must double-check AI-generated content. And courts will not tolerate fake precedent, no matter how it got there.

Technology changes fast. Professional responsibility doesnโ€™t.

This isnโ€™t just a Utah issueโ€”itโ€™s a turning point. Lawyers across the country should take note: due diligence is still non-negotiable.