A California judge has ordered a lawyer for State Farm to pay $999.99 after finding seven nonexistent case citations in pretrial filings, errors the attorney said stemmed from her use of an artificial intelligence legal research tool.
Los Angeles Superior Court Judge Elizabeth L. Bradley imposed the sanction on Jacquelene Robinson, a senior associate at Musick, Peeler & Garrett, who represents State Farm General Insurance Company in a homeowner lawsuit. The false authorities appeared in filings submitted ahead of an October trial.
Bradley’s $999.99 order falls one cent below a threshold that carries an additional consequence under California law. Courts generally must notify the State Bar when an attorney receives judicial sanctions of $1,000 or more, excluding certain discovery sanctions.
The citation problems surfaced as attorneys for homeowner Fa’alagilagi Meni-Siliga reviewed State Farm’s pretrial motions. Plaintiff attorney Eric Khodadian told the court that questionable authorities appeared in nearly every motion in limine filed on the insurer’s behalf.
Motions in limine ask a judge to decide before trial whether certain evidence or arguments can be presented to a jury. After the issue was raised during an August 7 court conference, Robinson reviewed the filings and confirmed that seven cited cases did not exist.
The filings also included incorrect case names and quotations that could not be found in the authorities cited.
Robinson said she used Irys, an AI legal research tool, while preparing the filings and believed the service was connected to her firm’s Westlaw subscription. She also believed the program performed an internal citation check.
She acknowledged that she relied on the tool without independently verifying every authority before the documents were filed.
In a declaration submitted before the sanctions hearing, Robinson accepted responsibility and apologized to Bradley. She told the court that citing fabricated authorities was unacceptable and said she had changed her research process.
Robinson said she now retrieves cited decisions through Westlaw, LexisNexis or another reliable source, checks quotations against the underlying opinions and conducts a citation review before filing. Authorities generated with AI must also be independently located and verified.
State Farm said it expects outside lawyers representing the company to comply with professional and ethical standards, including when using AI and reviewing court filings. The insurer said it was working with outside counsel to ensure safeguards were in place.
The sanction comes as courts continue to confront filings containing invented cases, false quotations and other material generated by AI. Judges have increasingly imposed monetary penalties when lawyers submit unverified authorities.
Days before Bradley’s order, the New Mexico Supreme Court fined a defense attorney $5,000 after a murder appeal included fabricated witness testimony and nonexistent information that the lawyer attributed to ChatGPT.
The State Farm filings arose from Meni-Siliga’s 2024 lawsuit over insurance coverage involving her former home in Carson, California. A 2020 fire left the property uninhabitable, and the house later suffered water damage during a storm while repairs were underway.
Meni-Siliga claims delays in handling the insurance matter contributed to the repairs remaining unfinished. State Farm disputes her allegations.
The underlying case is scheduled for trial on October 5.
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