Primerica Life Insurance Co. v. Finlayson
U.S. District Court, District of Utah · D. Utah · Utah bar guidance
Conduct
Counsel filed a brief with citations that could not be found on Westlaw, then attributed the defective citations to clerical error.
Consequence
Formal warning, no monetary sanction. Court admonished counsel to verify all citations against primary sources going forward.
Lesson
By 2026 'clerical error' is no longer a complete defense. A pre-filing verification step is the floor, not best practice.
Verified May 5, 2026
- Citation
- Primerica Life Ins. Co. v. Finlayson (D. Utah Apr. 22, 2026)
- Decided
- April 22, 2026
Summary
In an interpleader action involving Primerica Life Insurance Company and competing claimants Daniel Vett Finlayson and Michelle Johnson, counsel filed a brief containing multiple case citations that could not be located on Westlaw. When confronted, counsel attributed the defective citations to clerical and research errors. The court treated the filing as the product of unverified generative-AI assistance and issued a warning rather than monetary sanctions.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
The court declined to impose monetary sanctions and instead issued a formal warning, admonishing counsel to verify all citations against primary sources before filing in future matters.
Why does Primerica Life Insurance Co. v. Finlayson matter for law firms using AI?
A warning, not a fine, but the entry still belongs in the tracker. By April 2026, federal courts had largely stopped accepting “clerical error” as a complete defense to fabricated citations, and even a no-money disposition in a routine interpleader signals that judges are reading every brief through an AI-skepticism lens. For a managing partner, the takeaway is procedural: a written verification step before filing is now the floor, not a best practice.
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.
- Exact docket number not retrieved (PDF binary not parseable in this verification environment; CourtListener docket not located).
- Sanctioned attorney's name and firm not extracted from order.
- Judge's name not extracted from order.
- Specific number of fabricated citations not extracted.