Wilkes v. Canyons School District
U.S. District Court, District of Utah, Central Division · D. Utah · Utah bar guidance
Verified May 5, 2026
- Citation
- Wilkes v. Canyons Sch. Dist., No. 2:25-cv-00218-CMR (D. Utah Mar. 17, 2026) (ECF 38)
- Decided
- March 17, 2026
Summary
Plaintiffs Regan and Brandon Wilkes, represented by counsel, filed a 91-page Amended Complaint in this IDEA appeal that cited at least three nonexistent cases to support tolling of IDEA's two-year statute of limitations: F.C. v. Capistrano Unified School District (purportedly 9th Cir.), A.D. v. Puyallup School District No. 3 (purportedly 4th Cir. 2015), and A.S. v. Norwalk Public Schools (purportedly 6th Cir. 2017). The Sixth Cause of Action also misrepresented the holding of a real case, J.M. v. Francis Howell School District, 850 F.3d 944 (8th Cir. 2017). Defendants flagged the citations as "AI-generated hallucinations." Chief Magistrate Judge Cecilia M. Romero noted that plaintiffs' counsel had previously been admonished for improper AI use in Moulder v. Davis School District, No. 1:25-cv-00052-TS-CMR (D. Utah Jan. 28, 2026).
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Court reserved ruling on the Second and Sixth Causes of Action and set an Order to Show Cause hearing for April 14, 2026, at 10:00 A.M. to determine the effect of plaintiffs' use of false law on those claims and possible sanctions. The court separately dismissed the First Cause of Action (Section 1983), Fifth Cause of Action (Utah State Constitution), and the punitive damages claim without prejudice on independent grounds.
Why does Wilkes v. Canyons School District matter for law firms using AI?
Wilkes is a clear illustration that AI-hallucinated authority does not have to drive the merits of a motion to draw judicial scrutiny. The court reserved ruling on two causes of action and set a sanctions show-cause hearing solely because of fabricated citations buried in a 91-page complaint, observing that “the use of even one non-existent case undermines the credibility of the entire document.” The order also flags a repeat-offender pattern, citing the same firm’s prior AI admonishment in Moulder v. Davis School District two months earlier, a reminder that managing partners should treat a single AI citation incident as a firm-wide compliance signal, not an isolated lapse.
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.