Wyoming: AI Ethics Guidance for Law Firms

Bottom line for a 5-50 attorney Wyoming firm: No bar opinion, no mandatory disclosure rule, and no statewide state-court AI rule govern AI use in Wyoming as of 2026-09-30; the Wyoming Rules of Professional Conduct apply directly. The absence of guidance is not a safe harbor. In Wadsworth v. Walmart (D. Wyo. 2025) the court imposed Fed. R. Civ. P. 11 sanctions, including pro hac vice revocation, on every attorney who signed motions citing nonexistent cases. The District of Wyoming’s Local Criminal Rule 49.1(d) now requires review and verification of AI-generated content in criminal cases, and the Wyoming Chancery Court has treated hallucinated citations as a violation of its own Rule 11(b)(2).

Firms documenting compliance may wish to consider: a written AI use policy, a citation verification step before any court filing, and a vendor diligence record for each AI tool in use.

What governs by default

The Wyoming State Bar has issued no formal or informal ethics opinion on AI and has announced no AI task force or rulemaking proceeding. The Wyoming Rules of Professional Conduct apply directly. The rules in the page-level applicable-rules block carry their ordinary meaning when the firm uses AI; the AI-relevance notes there are not Wyoming-specific. Searched 2026-09-30: the Wyoming State Bar ethics and ethics-help pages, the Wyoming Supreme Court rule-amendment orders from November 2025 through September 2026, and its opinion database.

Wyoming Rule of Professional Conduct 1.1, Comment [8], states that “a lawyer should keep abreast of changes in the law and its practice, including the benefits and risks associated with relevant technology.” The comment was renumbered from [6] to [8] by amendment of February 6, 2024 (effective April 15, 2024), and now matches ABA Model Rule 1.1 Comment [8]. Bar Counsel Mark W. Gifford cited the comment in a non-binding Wyoming Lawyer article, “Transitioning to Generative AI? Don’t Leave the Rules of Professional Conduct Behind” (February 2024). A second Wyoming Lawyer article, “Balancing Innovation and Ethics: Using AI in the Legal Profession” (April 2025), is by Professor Melissa Ballengee Alexander of the University of Wyoming College of Law. Both are bar journal articles, not ethics opinions, and carry no advisory or binding authority.

ABA Formal Opinion 512 (July 2024) is consistent with the principles these articles discuss (competence, candor, confidentiality, supervision, fees) but has not been formally adopted by the Wyoming State Bar. The District of Wyoming’s General Order No. 25-01 refers litigants to it (“See, e.g., The American Bar Association Formal Opinion 512”).

What federal courts in Wyoming require for AI use in filings

On May 13, 2025, Chief Judge Scott W. Skavdahl signed General Order No. 25-01, “General Order Concerning the Use of Artificial Intelligence in the Preparation of Filings.” The order does not require a disclosure form. It states that “it is necessary to remind all litigants that appear in this court, represented or pro se, of their obligations under Rule 11,” that filing AI-generated citations to non-existent cases (also known as “hallucinated” legal authority) “is strictly prohibited and subject to sanction,” and that AI use “will not and does not excuse or absolve” Rule 11 compliance. See the tracker entry for General Order No. 25-01.

For criminal cases, Local Criminal Rule 49.1(d) (revision effective August 1, 2026) cautions that AI technology “may produce factual or legally inaccurate content” and provides that counsel or a party using AI “must review and verify any computer generated content to ensure that it complies with all such standards.”

What Wyoming state courts require for AI use in filings

No Wyoming Supreme Court rule, district court rule, or circuit court order governs AI use in state court filings as of 2026-09-30. The Wyoming Chancery Court has applied W.R.C.P.Ch.C. 11 to hallucinated citations: Chan v. Khermani LLC, 2024 WYCH 11, warning a self-represented plaintiff that “Any future filing by plaintiff that contains fictitious law will be subject to severe penalty”; Chagnon v. Nelson, 2025 WYCH 9, striking a self-represented party’s motion that included “improper and unsupported legal contentions in violation of W.R.C.P.Ch.C. 11(b)(2)”; and United Resources, LLC v. Bravo Multinational Inc., 2026 WYCH 29, where “The petition’s inclusion of law that appears to have been hallucinated weighs against exercise of the court’s discretion in granting a TRO.” District and circuit courts rely on existing obligations under WRPC 3.3 and Wyoming Rule of Civil Procedure 11(b).

Wadsworth v. Walmart (D. Wyo. 2025)

Citation: Wadsworth v. Walmart Inc., 348 F.R.D. 489 (D. Wyo. 2025). Sanctions order issued February 24, 2025 by U.S. District Judge Kelly H. Rankin (docket; text). See the tracker entry.

Three attorneys, Rudwin Ayala and T. Michael Morgan of Morgan & Morgan and local counsel Taly Goody of a California firm, signed motions in limine in a product liability case arising from a fire. The motions “cited nine cases, but eight did not exist.” Ayala had used MX2.law, “an in-house database launched by Mr. Ayala and Mr. Morgan’s firm, Morgan & Morgan,” to generate the citations. Sanctions under Rule 11 and the court’s inherent authority: Ayala $3,000 and pro hac vice admission revoked; Morgan $1,000; Goody $1,000.

Significance for Wyoming firms: Judge Rankin held that each signer owes a nondelegable duty to make a reasonable inquiry into the law cited. Quoting Mata v. Avianca, the court wrote that “A fake opinion is not ‘existing law.’” It added that “blind reliance on another attorney can be an improper delegation of this duty and a violation of Rule 11.” The court found that each signer violated Rule 11(b)(2), and it credited the attorneys’ remedial steps. The order does not rely on the Wyoming Rules of Professional Conduct. In May 2026 a Massachusetts court cited the Wadsworth sanction in denying Morgan’s pro hac vice motion in another matter (Wilder v. Harvard). In an appeal from the District of Wyoming, the Tenth Circuit cited Wadsworth in suspecting that a self-represented appellant’s quotation was “a fabrication generated by his use of a generative artificial intelligence (AI) tool,” and declined to sanction him (Jarvis v. County of Teton, No. 25-8034 (10th Cir. Apr. 24, 2026)).

What AI-related rules are pending in Wyoming?

Wyoming HB 102 (2026), enacted as 2026 Wyo. Sess. Laws ch. 91 (Enrolled Act No. 32) and effective July 1, 2026, provides that using AI to commit a criminal offense “shall not be a defense,” creates offenses concerning synthetic sexual material and AI used against children and AI used to promote self-harm or to censor political speech, and limits AI developer liability. It does not regulate attorney professional conduct or law firm AI use.

At the federal level, Senator Cynthia Lummis (R-WY) introduced the Responsible Innovation and Safe Expertise (RISE) Act of 2025 as S. 2081 on 2025-06-12. It was read twice and referred to the Senate Committee on Commerce, Science, and Transportation, with no later action as of 2026-09-30. The bill would make AI developers immune from civil liability for errors when a learned professional uses their product, conditioned on the developer publishing a model card and model specification. Its findings state that professionals using AI “have professional obligations to understand the capabilities and limitations of the tools they employ,” and Senator Lummis’s announcement described the bill as meaning “licensed professionals are ultimately responsible for the advice and decisions they make.”

As of 2026-09-30 the Wyoming State Bar has announced no AI task force or draft opinion.

How do malpractice carriers in Wyoming treat AI use?

ALPS is the Wyoming State Bar’s endorsed professional liability carrier. In an August 2025 risk-management article, ALPS noted that existing LPL exclusions could reach some AI-related claims, including the unauthorized-practice exclusion where AI makes “critical legal judgements without attorney oversight.” The Wyoming State Bar’s risk-management page points members to ALPS’s free Virtual Ethics Risk Assessment (VERA). No filed AI exclusion has been located in the admitted lawyers professional liability market, and no Wyoming-specific AI endorsement has been identified.

What does my Wyoming malpractice carrier ask about AI at renewal?

ALPS has not published Wyoming-specific AI application questions. Of the LPL application forms reviewed for this site, only AmTrust’s (form LPLPRO-APP-01 0523) asks about AI, with a checkbox for “Allow the use of Artificial Intelligence software to draft documents. If checked, please attach description.” WTW’s 2026 marketplace report reports underwriters focusing on law firms’ controls over AI use. Firms documenting compliance may wish to keep the records an underwriter or court could ask about: a written AI use policy, training records, vendor due-diligence records for each tool, and a citation-verification protocol. Those records map to WRPC 1.1, 1.6, 3.3, 5.1, and 5.3, General Order No. 25-01, and Local Criminal Rule 49.1(d).

What documentation should a Wyoming firm keep on file?

Month one (foundational)

1. (Owner: managing partner + firm administrator) Written AI use policy (WRPC 1.1, 1.6, 5.1, 5.3). Identify approved tools, classify each as closed-enterprise or open-consumer, prohibit submitting unverified AI output to courts or clients, and assign supervision for AI tasks performed by associates, paralegals, and staff. In Wadsworth, the drafting attorney, a partner who signed without reviewing, and local counsel were all sanctioned.
2. (Owner: litigation lead) Citation verification log per filing (WRPC 3.3; Fed. R. Civ. P. 11; W.R.Civ.P. 11(b)). Pre-filing step requiring independent verification of every cited authority against Westlaw, Lexis, or the primary source. Local Criminal Rule 49.1(d) requires verification of AI-generated content in D. Wyo. criminal cases, and Wadsworth shows the Rule 11 exposure in civil cases.
3. (Owner: litigation lead) D. Wyo. General Order No. 25-01 and L.Cr.R. 49.1(d) checklist (Fed. R. Civ. P. 11; L.Cr.R. 49.1(d)). For every federal filing in the District of Wyoming, confirm AI-generated content has been reviewed and all citations verified. Neither the order nor the rule requires a disclosure form; both place the verification obligation on the filer.

Months two and three (operational documentation)

1. (Owner: firm administrator + outside IT) Vendor due diligence file (WRPC 1.6). For each AI tool used with client information, capture: data retention and training-opt-out documentation, vendor contract or terms of service, classification as closed or open system, date of review, and responsible attorney.
2. (Owner: firm administrator) Attorney and staff training log (WRPC 1.1, 5.1, 5.3). Capture date, attendees, and content of AI training: hallucination risk, candor obligations under WRPC 3.3, verification procedures, confidentiality under WRPC 1.6, and the firm’s AI use policy.
3. (Owner: managing partner + billing partner) Engagement letter provision (WRPC 1.5, 1.6). Address AI use in the engagement agreement or addendum: which tools may be used, whether client information may be submitted to external servers, consent for open-model tools, and how time savings or AI subscription costs are reflected in billing.

Months four to six (per-matter discipline)

These are recurring practices, not one-time projects: each new matter exercises them.

1. (Owner: matter lead attorney) Pro hac vice compliance documentation for D. Wyo. matters (WRPC 5.1; Fed. R. Civ. P. 11). Firms serving as local counsel for out-of-state co-counsel may wish to document that all co-counsel have reviewed General Order No. 25-01 and the firm’s verification protocol. In Wadsworth, local counsel who signed the motions was fined $1,000, and one attorney’s pro hac vice admission was revoked.
2. (Owner: matter lead attorney) Incident response record (WRPC 3.3). If AI-generated content with errors reaches a court filing or client deliverable, document the discovery, the correction made, and any disclosure to the court or client. Wadsworth credited the attorneys’ remedial steps, including prompt withdrawal of the motions and candor about AI use.

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