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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Garner v. Kadince
CA Utah · May 22, 2025
UT / stateEditorial impact: mediumfake citationscontractappellate
Direct answer
What happened in this matter?
Fabricated: Case Law | Fabricated appellate case cited in the Petition; opposing counsel showed it appears only in ChatGPT and not in any legal database, and the court sanctioned counsel for relying on fake precedent.
- Why the court cared
- The panel (Per Curiam) emphasized that the conduct, while not malicious, still diverted judicial resources and imposed unnecessary burdens on the opposing party. Unlike Mata or Hayes, the attorneys in this case quickly admitted the issue and cooperated, which the court acknowledged. Nonetheless, the submission of fabricated law—especially under counsel's signature—breaches core duties of candor and verification, warranting formal sanctions. The court warned that Utah’s judiciary cannot be expected to verify every citation and must be able to trust lawyers to do so
- Why it matters now
- Ban unsupervised AI use by non-lawyer staff and require attorney review of every filing before submission.
Why this matter is tracked
Fabricated: Case Law | Fabricated appellate case cited in the Petition; opposing counsel showed it appears only in ChatGPT and not in any legal database, and the court sanctioned counsel for relying on fake precedent.
AI Use
The fabricated citations originated from a ChatGPT query submitted by an unlicensed law clerk at Petitioner's law firm. Neither Counsel reviewed the petition’s contents before filing. The firm had no AI use policy in place at the time, though they implemented one after the order to show cause was issued.
Hallucination Details
Chief among the hallucinations was Royer v. Nelson, which Respondents demonstrated existed only in ChatGPT’s output and in no official database. Other cited cases were also inapposite or unverifiable. Petitioner’s counsel admitted fault and stated they were unaware AI had been used during drafting.
Ruling/Sanction
The court issued three targeted sanctions:Attorney fees: Respondents’ counsel are to submit an itemized bill; Counsel must pay within 10 days of receiptClient refund: Petitioner’s counsel must refund all fees paid by Mr. Garner in relation to the defective petitionCharitable payment: Counsel must donate $1,000 to “and Justice for all” within 14 days and file proof of payment with the court
Key Judicial Reasoning
The panel (Per Curiam) emphasized that the conduct, while not malicious, still diverted judicial resources and imposed unnecessary burdens on the opposing party. Unlike Mata or Hayes, the attorneys in this case quickly admitted the issue and cooperated, which the court acknowledged. Nonetheless, the submission of fabricated law—especially under counsel's signature—breaches core duties of candor and verification, warranting formal sanctions. The court warned that Utah’s judiciary cannot be expected to verify every citation and must be able to trust lawyers to do so
Operational lesson
Ban unsupervised AI use by non-lawyer staff and require attorney review of every filing before submission.
Record details
UtahSingle-state evidence scope
CourtCA Utah
Jurisdictionstate
Circuit10th Circuit
DateMay 22, 2025
CH
AI toolChatGPT
Party typeLawyer
OutcomeSee source
Known amount$1,000
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
ChatGPT is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Procedural posture is not separately recorded in the current dataset.
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Fabricated appellate case cited in the Petition; opposing counsel showed it appears only in ChatGPT and not in any legal database, and the court sanctioned counsel for relying on fake precedent.
Questions this record answers
- What happened in Garner v. Kadince?
- Fabricated: Case Law | Fabricated appellate case cited in the Petition; opposing counsel showed it appears only in ChatGPT and not in any legal database, and the court sanctioned counsel for relying on fake precedent.
- Why does Garner v. Kadince matter for legal AI risk?
- Ban unsupervised AI use by non-lawyer staff and require attorney review of every filing before submission.
- What does the public record establish about Garner v. Kadince?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Garner v. Kadince summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.