SALT LAKE CITY (LN) — Chief Magistrate Judge Cecilia M. Romero of the U.S. District Court for the District of Utah ordered attorneys Tyler Ares and Amy Martz to pay the sanction after they admitted to using AI software that distorted real case names into non-existent ones in a complaint against the Canyons School District.
Romero ruled that the attorneys violated Federal Rule of Civil Procedure 11 by failing to verify the existence of the cases they cited. The court expressed skepticism regarding the attorneys’ explanation that the AI software, used to polish their writing, inadvertently altered the citations. The judge noted that the holdings of the “correct” cases cited in a supplemental filing did not match the legal arguments presented complaint.
The ruling follows recent Tenth Circuit decisions holding that relying on non-existent cases is sufficient grounds to dismiss an appeal. In this case, Romero denied the defendants’ request to dismiss the entire complaint as a sanction. However, she separately granted a partial dismissal of the plaintiffs’ Second Cause of Action, which alleged violations of the Individuals with Disabilities Education Act, on statute of limitations grounds.
The court limited the IDEA claim to violations occurring within two years of the plaintiffs filing their due process complaint on October 16, 2024. Romero rejected the plaintiffs’ argument that the statute of limitations should be tolled, finding they failed to adequately plead that school district misrepresentations prevented them from seeking a hearing earlier.
The parties stipulated to the $7,000 monetary sanction to reimburse the school district for legal expenses incurred addressing the fabricated citations. Romero noted that Ares and Martz were previously ordered to complete two continuing legal education courses on AI ethics in a separate case, Moulder v. Davis School District. Because that requirement remains outstanding, the judge determined the monetary sanction alone was sufficient to deter future misconduct.