Primerica Life Insurance Company v. Daniel Vett Finlayson; Michelle Johnson
D. Utah · Apr 22, 2026
What happened in this matter?
The Court issued a formal warning to counsel regarding the potential improper use of AI after counsel submitted filings containing fabricated case law and inaccurate quotations. The Court cautioned counsel to exercise greater care in future submissions but did not impose monetary or professional sanctions.
- Why the court cared
- The Court reasoned that the initial opposition was riddled with unlocatable citations and inaccurate quotations, and counsel's inability to provide the source material upon request, combined with the nature of the errors, suggested improper AI use. The Court denied the motion to amend because the proposed filing did not offer new material evidence or address newly raised issues, and the Court already understood the legal arguments.
- Why it matters now
- Westlaw-unlocatable cites are a red flag; verify every citation on the platform before it leaves the office.
Why this matter is tracked
In a civil interpleader action, the District Court for the District of Utah addressed a motion for leave to file an amended opposition to summary judgment after counsel for Cross Claimant Michelle Johnson submitted an initial opposition containing multiple unlocatable case citations and inaccurate quotations. Upon the Court's inquiry, counsel admitted to clerical and research errors. The Court noted that the opposition appeared to result from the improper use of artificial intelligence. While the Court expressed concern regarding the potential AI use and cautioned counsel to exercise greater care in future filings, it ultimately denied the motion for leave to amend on procedural grounds, finding the proposed amendment unnecessary, and proceeded to rule on the merits of the summary judgment motion.
Westlaw-unlocatable cites are a red flag; verify every citation on the platform before it leaves the office.
Record details
What the record establishes about AI use
The Court explicitly referenced the improper use of artificial intelligence.
The matter was before the Court on a Motion for Summary Judgment and a Motion for Leave to File an Amended Memorandum in Opposition. The Court denied the motion to amend and granted in part and denied in part the motion for summary judgment.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Opposition contained multiple case citations the Court could not locate on Westlaw; counsel later confirmed clerical/research errors and the Court suggested possible improper AI use.
- False Quotes: Case Law | Opposition included quotations attributed to cases that the Court could not verify; the quotations were inaccurate or unlocatable.
Questions this record answers
- What happened in Primerica Life Insurance Company v. Daniel Vett Finlayson; Michelle Johnson?
- The Court issued a formal warning to counsel regarding the potential improper use of AI after counsel submitted filings containing fabricated case law and inaccurate quotations. The Court cautioned counsel to exercise greater care in future submissions but did not impose monetary or professional sanctions.
- Why does Primerica Life Insurance Company v. Daniel Vett Finlayson; Michelle Johnson matter for legal AI risk?
- Westlaw-unlocatable cites are a red flag; verify every citation on the platform before it leaves the office.
- What does the public record establish about Primerica Life Insurance Company v. Daniel Vett Finlayson; Michelle Johnson?
- 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 Primerica Life Insurance Company v. Daniel Vett Finlayson; Michelle Johnson 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.