Was Garner v. Kadince sanctioned over AI-generated citations?

Garner v. Kadince (Utah C.A., May 22, 2025) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Monetary penalty: $1,000 plus fee refund and opposing fees. $1,000 in monetary penalties.

Which AI tool was involved in Garner v. Kadince?

The matter records ChatGPT as the generative tool associated with the unverified citations in Garner v. Kadince.

May 22, 2025 · AI sanctions database

Garner v. Kadince

Garner v. Kadince is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: Utah C.A.
Date: May 22, 2025
Party: Lawyer
AI tool: ChatGPT
Outcome: Monetary penalty: $1,000 plus fee refund and opposing fees
Penalty: $1,000 in monetary penalties.

Fine

What the record shows

Petitioner's counsel acknowledged that the petition contained fabricated legal authority obtained from ChatGPT, including a citation the court found does not appear in any legal database. The court ordered counsel to pay opposing fees, refund all fees charged to the petitioner, and directed Mr. Bednar to pay $1,000 as a donation to 'and Justice for all' for failing to meet obligations under rule 40 of the Utah Rules of Appellate Procedure.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · Utah C.A.

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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