Moulder v. Davis School District
U.S. District Court, District of Utah · D. Utah · Utah bar guidance
Verified April 26, 2026
- Citation
- Moulder v. Davis School District, No. 1:25-cv-00052-TS-CMR (D. Utah Mar. 23, 2026)
- Decided
- March 23, 2026
Summary
Plaintiffs' counsel Tyler Ares and Amy Martz, both solo practitioners representing the Moulders on behalf of minor child M.M., filed briefing containing two non-existent cases and one non-existent quote generated by AI. After defendants' counsel flagged the fabrications, the attorneys agreed to reimburse $1,525.50 in legal fees, and District Judge Ted Stewart later issued an Order to Show Cause. At the March 11, 2026 hearing, counsel admitted using AI to prepare arguments and failing to verify the citations, accepting full responsibility for the Rule 11(b) violation.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,525.50
What sanction did the court impose?
Judge Stewart imposed sanctions under Rule 11(c)(1), crediting the $1,525.50 already reimbursed to defendants' counsel as partial fee compensation, and ordered Ares and Martz to complete two CLE courses on AI ethics and professional responsibility within six months and submit proof of completion to the Court.
Why does Moulder v. Davis School District matter for law firms using AI?
Moulder illustrates a pattern federal judges are increasingly comfortable with: when solo or small-firm counsel admit the AI misuse, accept responsibility, and demonstrate remediation steps such as citation-verification software and added staff, courts trend toward modest fee reimbursement plus mandatory AI-ethics CLE rather than escalated discipline. For managing partners, the practical lesson is that documented verification workflows and post-incident remediation materially shape the sanction the court will impose.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.