Wyoming: AI Ethics Guidance for Law Firms

Bottom line for a 5-50 attorney Wyoming firm: No formal bar opinion, no mandatory disclosure rule, and no statewide court AI order govern AI use in Wyoming today; the Wyoming Rules of Professional Conduct apply directly. The absence of guidance is not a safe harbor: Wadsworth v. Walmart (D. Wyo. 2025) shows that filing unverified AI-generated citations triggers Fed. R. Civ. P. 11 and WRPC 3.3 sanctions, including pro hac vice revocation. A firm without a written AI use policy and citation verification practice is already exposed.

Start with: 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.

Wyoming has adopted WRPC Rule 1.1 with Comment 6, the Wyoming counterpart of ABA Model Rule 1.1 Comment 8. The comment requires lawyers to keep abreast of the benefits and risks of relevant technology. Bar Counsel Mark W. Gifford has cited that comment as the foundation for AI competence in two non-binding educational articles in the Wyoming Lawyer: “Transitioning to Generative AI? Don’t Leave the Rules of Professional Conduct Behind” (February 2024) and “Balancing Innovation and Ethics: Using AI in the Legal Profession” (April 2025). 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 Gifford articulates (competence, candor, confidentiality, supervision, fees) but has not been formally endorsed by the Wyoming State Bar.

What federal courts in Wyoming require for AI use in filings

On 2025-05-13, the U.S. District Court for the District of Wyoming issued General Order 2025-01, “General Order Concerning the Use of Artificial Intelligence in the Preparation of Filings.” The order does not require a disclosure form. It reminds all litigants and counsel that legal contentions in court filings must be warranted by existing law under Fed. R. Civ. P. 11, that attorneys certify as much by signing each document, and that a fake opinion is not “existing law.” Verification of any AI-generated content is the affirmative obligation; disclosure is not. See the tracker entry for D. Wyo. General Order 25-01.

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. State courts rely on existing obligations under WRPC Rule 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 2025-02-24 by U.S. District Judge Kelly H. Rankin.

Three attorneys, including Rudwin Ayala and supervising partner T. Michael Morgan of Morgan & Morgan and local counsel Taly Goody, filed motions in limine citing nine cases in a product liability matter involving an allegedly defective hoverboard. Eight of the nine did not exist. Ayala had used his firm’s in-house tool, MX2.law, to generate the citations and none of the attorneys verified them before signing and filing. Sanctions: Ayala $3,000 and pro hac vice admission revoked; Morgan $1,000; Goody $1,000.

Significance for Wyoming firms: Judge Rankin held that signing a document creates a nondelegable personal duty to verify cited law: “a fake opinion is not ‘existing law’” and “blind reliance on another attorney can be an improper delegation of this duty.” The court rejected the argument that the supervising partner bore no responsibility for a subordinate’s AI-hallucinated filings. Use of a firm-branded AI tool did not constitute a reasonable inquiry. The case establishes three holdings. Fed. R. Civ. P. 11 applies to AI-generated content with no AI-specific exception. Supervision duties under WRPC 5.1 extend to AI use by subordinates. Pro hac vice admission may be revoked as an AI-hallucination sanction.

What AI-related rules are pending in Wyoming?

Wyoming HB 0102 (2025), enacted and effective 2026-07-01, addresses deepfakes involving minors, nonconsensual synthetic sexual material, AI systems promoting self-harm, AI-as-criminal-defense, and developer civil liability. It does not regulate attorney professional conduct or law firm AI use. Two general AI governance bills considered by the Legislature’s Select Committee on Blockchain, Financial Technology and Digital Innovation Technology were set aside in September 2024 without enactment.

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. The bill was read twice and referred to the Senate Committee on Commerce, Science, and Transportation. If enacted, it would codify that licensed professionals using AI retain the duty to verify outputs and stand behind their advice.

The Wyoming State Bar has announced no AI task force or draft opinion in progress.

How do malpractice carriers in Wyoming treat AI use?

Wyoming does not require malpractice insurance as a condition of bar membership. ALPS Corporation is the Wyoming State Bar’s endorsed professional liability carrier. ALPS has published national guidance flagging that over-reliance on AI without attorney review may implicate unauthorized-practice exclusions in many LPL policies, and that allowing AI to make legal judgments without oversight can create coverage gaps. ALPS offers a Virtual Ethics Risk Assessment (VERA) tool and separate cyber liability coverage. No Wyoming-specific AI endorsement or exclusion has been identified.

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

ALPS has not published Wyoming-specific AI application items. Its national guidance points firms to documented attorney oversight of AI output, vendor due diligence, and policy review as the substantive standard. That guidance is consistent with WRPC 1.1, 1.6, 3.3, 5.1, and 5.3 and with the verification obligation reinforced by General Order 2025-01 and Wadsworth. Plan on producing a written AI use policy, training records for attorneys and staff, vendor due-diligence records for each tool in use, and a citation-verification protocol. Firms should review renewal applications carefully and answer AI-use questions accurately. Carriers nationally are beginning to ask AI-related questions even where Wyoming-specific items have not been published.

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. Wadsworth establishes that both the using attorney and the supervising partner are exposed.
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. Mandatory as a practical matter in D. Wyo. after Wadsworth.
3. (Owner: litigation lead) D. Wyo. General Order 2025-01 compliance checklist (Fed. R. Civ. P. 11). For every federal filing in the District of Wyoming, confirm AI-generated content has been reviewed and all citations verified. The order does not require a disclosure form. The verification obligation is affirmative.

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). Wyoming-licensed counsel supervising out-of-state co-counsel should document that all co-counsel have reviewed General Order 2025-01 and the firm’s verification protocol. Wadsworth revoked one attorney’s pro hac vice admission for verification failure.
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. Prompt voluntary correction is a material mitigating factor; the failure to catch the hallucinations before filing was the core violation in Wadsworth.

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