D. Wyo.: U.S. District Court for the District of Wyoming, General Order 25-01: Use of Art…
Chief U.S. District Judge Scott W. Skavdahl · United States District Court for the District of Wyoming
Verified September 30, 2026
- Citation
- U.S. District Court for the District of Wyoming, General Order 25-01: Use of Artificial Intelligence in the Preparation of Filings
- Order date
- May 13, 2025
Summary
The order reminds '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.'
What does the order require?
- The order reminds '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.'
- Filing AI-generated 'citations to non-existent cases (also known as "hallucinated" legal authority)' is 'strictly prohibited and subject to sanction.'
- The court does not require an AI disclosure form or certification block. Rule 11 supplies the duty: using AI does not excuse or absolve a litigant's required compliance with Rule 11.
- Sanctions 'may include fines, non-monetary directives such as completing educational programs, reporting to the disciplinary boards of the bars of which the attorney is a member, and other appropriate and necessary sanctions. Repeated violations may result in disbarment or filing restrictions.'
- '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.'
Practice areas: federal civil, federal criminal
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 Rule 11 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 reminds filers that Rule 11 requires legal contentions to be warranted by existing law, and it reaffirms that Fed. R. Civ. P. 11 supplies the operative duty. It prescribes no separate verification step, so this entry records it as binding without an AI-specific verification facet.
- 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.”
- 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.”
- AI use does not excuse Rule 11 compliance. “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.”
- 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.
- Sanctions toolkit. Fines, non-monetary directives such as completing educational programs, reports to the disciplinary boards of the bars of which the attorney is a member, 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 plaintiffs’ attorneys in Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. 2025): Rudwin Ayala and T. Michael Morgan of Morgan & Morgan, and local counsel Taly Goody, whose firm is in California. Their motions in limine “cited nine cases, but eight did not exist.” Judge Kelly H. Rankin’s sanctions order (Feb. 24, 2025) revoked Mr. Ayala’s pro hac vice admission and fined him $3,000, and fined Mr. Morgan and Ms. Goody $1,000 each. 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 for filers using AI tools (“Please be mindful of this when utilizing AI tools.”).
Practitioner workflow
For D. Wyo. civil matters, the order requires no AI disclosure block and prescribes no verification step of its own; the operative duty is Rule 11’s reasonable inquiry. Firms documenting compliance may wish to keep a contemporaneous record showing each citation was checked against Westlaw, Lexis, or the primary source before the document was signed. Wadsworth treats each signer’s Rule 11 duty as personal: “blind reliance on another attorney can be an improper delegation of this duty and a violation of Rule 11,” which bears on supervising partners and on pro hac vice and local counsel alike. In criminal cases, Local Criminal Rule 49.1(d) separately requires counsel or parties who use AI to review and verify any computer-generated content.
Scope
District of Wyoming federal court only. Applies to all litigants appearing in the court, represented and pro se. In criminal cases, Local Criminal Rule 49.1(d) (in the rules revised August 1, 2026) also cautions counsel and parties using AI and requires them to “review and verify any computer generated content.” 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