Incident Tracker

Garner v. Kadince, Inc., 2025 UT App 80

sanctions

In the Utah Court of Appeals, petitioner's counsel filed a brief containing ChatGPT-fabricated citations, including a non-existent 'Royer v. Nelson', violating appellate rule 40. The court sanctioned attorney Richard Bednar, ordering him to donate $1,000 to a legal-aid charity and to pay the respondents' fees and refund his client.

Date of decision/order

2025-05-22

Court

Utah Court of Appeals

Jurisdiction

US-STATE

AI tool

ChatGPT

Conduct

Petitioner's counsel filed a petition containing fabricated authority generated by ChatGPT, including a non-existent 'Royer v. Nelson, 2007 UT App 74'. After an order to show cause, the court found the filing violated appellate rule 40. Counsel Richard Bednar acknowledged the fabricated authority came from ChatGPT.

Consequence

USD 1,000