Wyoming has no formal AI guidance for attorneys, but it has one of the most dramatic AI sanctions cases in the country. In Wadsworth v. Walmart Inc. (D. Wyo. 2025), a federal judge imposed a $3,000 sanction and revoked an attorney's pro hac vice admission after the attorney filed a motion containing 8 out of 9 hallucinated case citations.
AI Regulation in Wyoming: The Current Landscape
Wyoming's AI regulatory picture is defined by a stark contrast: zero formal guidance from the state bar and one of the harshest federal sanctions cases in the nation. The Wyoming State Bar hasn't issued an ethics opinion, formed a task force, or published any guidance on AI in legal practice as of April 2026.
But the Wadsworth v. Walmart Inc. case (D. Wyo. 2025) tells a different story from the court side. A federal judge sanctioned an attorney $3,000 and revoked their pro hac vice admission after discovering that 8 out of 9 case citations in a filed motion were AI-generated hallucinations. That's not just a fine — it's removal from the case. The court effectively said: if you can't verify your AI-generated work, you can't practice here.
For Wyoming's roughly 1,500 attorneys — the smallest bar in the nation by count — this case carries enormous weight. It demonstrates that federal courts in Wyoming won't wait for bar guidance to impose consequences for AI-generated errors. The court used existing rules on competence and candor to deliver one of the most severe AI-related sanctions in the country.
What the Wyoming Bar Says About AI
The Wyoming State Bar has not issued any formal AI-specific ethics opinion or guidelines as of April 2026. No task force, no advisory opinion, no informal guidance. This makes Wyoming one of the least-guided states on AI in legal practice from a bar perspective.
The irony is that Wyoming has one of the most instructive AI cases in the country. Wadsworth v. Walmart shows exactly what happens when AI-generated work goes unchecked — $3,000 in sanctions and pro hac vice revocation for 8 out of 9 hallucinated citations. The bar hasn't translated this case into formal guidance, but every Wyoming attorney should treat it as de facto guidance on what not to do.
With 1,500 attorneys in the entire state, Wyoming's bar has limited resources for developing AI-specific guidance. But the Wadsworth case creates urgency. It's one thing for a bar to be silent on AI when nothing has happened. It's another to remain silent after a federal judge in the state has delivered a landmark sanctions decision.
Court Rules and Judicial Guidance
The Wadsworth v. Walmart Inc. decision (D. Wyo. 2025) is the most significant court-level AI action in Wyoming. The court didn't need an AI-specific local rule to act — it used existing authority over attorney conduct to impose $3,000 in sanctions and revoke pro hac vice admission.
The pro hac vice revocation is particularly notable. It goes beyond financial sanctions to exclude the attorney from practicing in the case entirely. This is a more severe consequence than most AI sanctions cases nationally, where courts typically impose fines or require remedial action.
No Wyoming state courts have issued standing orders or local rules on AI as of April 2026. But the Wadsworth case establishes that the U.S. District Court for the District of Wyoming is prepared to take strong action on AI-related filing failures.
Practical Implications for Wyoming Attorneys
Wadsworth v. Walmart changes the risk calculation for every attorney who files in Wyoming federal court. The case demonstrates three things: AI-generated hallucinated citations will be caught, the consequences will be severe, and existing rules are sufficient to punish the failure.
For Wyoming's 1,500 attorneys — concentrated in Cheyenne and Casper — the small bar size amplifies the reputational impact. Everyone knows everyone. A sanctions case or pro hac vice revocation in Wyoming's small legal community is career-altering in ways it wouldn't be in a market with 100,000 attorneys.
The absence of formal bar guidance combined with an active sanctions case creates a specific risk profile. Attorneys know the consequences (Wadsworth) but don't have a bar-endorsed framework for compliance. There's no checklist to follow, no approved workflow to adopt. Each attorney must develop their own AI verification practices and hope they're sufficient if challenged.
What Attorneys in Wyoming Should Do
Read the Wadsworth v. Walmart decision. It's the closest thing Wyoming has to AI guidance, and it comes from a federal judge rather than the bar. Understand what went wrong — 8 out of 9 fabricated citations — and build your practice to make that impossible in your filings.
Implement a zero-tolerance verification policy for AI-generated legal research. Every case citation, every statutory reference, every factual claim needs independent confirmation through traditional research tools. In Wyoming, the Wadsworth case means a failure to verify isn't just an ethical risk — it's a demonstrated path to sanctions and case removal.
Given Wyoming's small bar and limited formal guidance, consider adopting the framework from a state with comprehensive guidance. Oregon's Formal Opinion 2025-205 or the ABA's Formal Opinion 512 provide detailed, practical frameworks. Applying a more rigorous standard than Wyoming technically requires is the safest approach when the consequences of failure are as severe as Wadsworth demonstrates.
The Bottom Line
Wyoming's bar hasn't said a word about AI, but its federal court has spoken loudly. Wadsworth v. Walmart — $3,000 sanctions and pro hac vice revocation for 8 out of 9 hallucinated citations — is one of the harshest AI sanctions cases in the nation. For Wyoming's 1,500 attorneys, that case IS the guidance.
AI-Assisted Research. This piece was researched and written with AI assistance, reviewed and edited by Manu Ayala. For deeper takes and the perspective behind the research, follow me on LinkedIn or email me directly.