D. Wyo.: U.S. District Court for the District of Wyoming, General Order 25-01: Use of Art…

What the order requires

Chief U.S. District Judge Scott W. Skavdahl signed General Order 25-01 on May 13, 2025. The order is a verification reminder rather than a disclosure mandate. It does not require attorneys or pro se parties to flag AI use on the face of a filing. It does require that every cited authority be verified against existing law before signing, and it reaffirms that Fed. R. Civ. P. 11 supplies the operative duty.

1. Rule 11 applies, with no AI exception. “[I]t is necessary to remind all litigants that appear in this court, represented or pro se, of their obligations under Rule 11 of the Federal Rules of Civil Procedure. Rule 11 requires legal contentions in documents filed with a court be warranted by existing law.”
2. Hallucinated citations are sanctionable per se. Filings that “use AI which generate citations to non-existent cases (also known as ‘hallucinated’ legal authority)… [are] strictly prohibited and subject to sanction.”
3. AI use does not excuse the verification duty. “The fact that AI was used in or generated the offending document or filing will not and does not excuse or absolve a litigants’ required compliance with Rule 11.”
4. No required disclosure form. Unlike the District of Kansas Standing Order 26-01 (which reserves the court’s discretion to require sworn disclosure statements), D. Wyo. General Order 25-01 imposes no disclosure block, no certification language, and no per-filing AI declaration.
5. Sanctions toolkit. Fines, non-monetary directives such as completing educational programs, disciplinary referrals to the attorney’s home-state bar, and “other appropriate and necessary sanctions.” Repeated violations “may result in disbarment or filing restrictions.”

Context

The order was issued roughly 11 weeks after the District of Wyoming sanctioned three Morgan & Morgan attorneys in Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. 2025) for filing motions citing eight non-existent AI-generated cases. Judge Kelly H. Rankin’s sanctions order in Wadsworth (Feb. 24, 2025) revoked one attorney’s pro hac vice admission and imposed a combined $5,000 in fines. General Order 25-01 codifies the principle Wadsworth applied: signing is the act that creates personal Rule 11 exposure, regardless of which AI tool generated the underlying text.

The order also expressly cites “The American Bar Association Formal Opinion 512 - A guide to using AI ethically” as a reference, signaling that ABA Formal Opinion 512 (July 2024) is the framework D. Wyo. judges will look to when evaluating reasonable inquiry under Rule 11(b).

Practitioner workflow

For D. Wyo. matters, a Wyoming firm or out-of-state pro hac vice counsel does not need to add an AI disclosure block to filings. The firm does need a citation verification protocol that produces a contemporaneous record showing each citation was checked against Westlaw, Lexis, or the primary source before the document was signed. Given Wadsworth, supervising partners should document that subordinates’ AI-assisted drafts were reviewed and verified before filing; pro hac vice attorneys should treat the verification step as a personal, nondelegable obligation tied to their bar admission status.

Scope

District of Wyoming federal court only. Applies to all litigants appearing in the court, represented and pro se. The order does not bind Wyoming state courts; the Wyoming State Bar has issued no formal AI ethics opinion as of April 2026.

Primary source

General Order 25-01 (PDF): https://www.wyd.uscourts.gov/sites/wyd/files/General%20Order%20re%20Use%20of%20Artificial%20Intelligence%20in%20the%20Preparation%20of%20Filings.pdf