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Los Angeles judge sanctions State Farm's outside lawyer $999.99 over motions citing non-existent cases; the lawyer said she prepared them with the AI tool Irys

A Los Angeles County Superior Court judge ordered a senior associate at Musick, Peeler & Garrett, the outside firm defending State Farm in a homeowner's lawsuit over a fire-damaged home, to pay a $999.99 sanction after the associate's motions in limine cited cases, quotations and holdings that did not exist, Law360 reported on 14 September 2026. In a declaration reproduced by Reason's Volokh Conspiracy, the associate said she used an AI program called Irys to prepare the motions, did not check some of the citations, and wrongly believed the program was cite-checked through the firm's Westlaw subscription; she confirmed seven non-existent case citations across eight motions. The plaintiff's lawyers found the citations and raised them at a status conference on 7 August 2026. The firm acknowledged citations that appeared to be AI hallucinations, and its lead trial counsel apologised to the court and the plaintiff. According to Law360, the judge had considered up to $5,000, and the amount set is one cent below the level at which California law requires a court to notify the State Bar.

AI system
Irys (reported)
Occurred
31 Mar 2026 to 11 Sept 2026
Reported
18 August 2026
Event location
United States
What the AI did
Communicated with the person
Reported harm
Financial LossLegal Harm
Whose AI use
Their own AI use
Setting
Justice · Work
Evidence
AI involvement supported · Causal attribution supported · 4 sources
9 claims: 1 corroborated, 8 reported. 4 open questions
People reported harmed
1 person

AI system as recorded: Irys, an AI legal research program that the lawyer told the court she used to prepare the motions; Law360 says it appears to be the tool built by Iqidis Inc.

What Happened

The motions. In a homeowner's suit against State Farm and others in Los Angeles County Superior Court over the repair of a fire-damaged home, State Farm's outside firm, Musick, Peeler & Garrett, filed motions in limine seeking to exclude evidence from the coming trial. In a declaration reproduced by Reason's Volokh Conspiracy, the associate who was primarily responsible for the motions said that the first five were filed and served on 31 March 2026, that she used an AI program called Irys to prepare them, and that she did not check some of the citations because she believed, wrongly, that the program was tied to the firm's Westlaw subscription and performed a cite check. Her review confirmed seven case citations across eight motions that did not exist. Law360 says Irys appears to be the legal research tool built by Iqidis Inc.

Discovery. The plaintiff's lawyers raised the citations with the court at the close of a final status conference on 7 August 2026. CalMatters quotes their filing as finding cases, quotations and holdings that do not exist; Law360 reports that one of them counted seven made-up cases, nine quotations from orders that did not exist and 13 fabricated holdings or statements of law. The firm acknowledged citations that appeared to be AI hallucinations, filed redlined copies of the affected motions, and its lead trial counsel apologised to the court and the plaintiff, saying he had not known AI was used and that the firm had updated its AI policy.

Sanction. According to Law360, the judge's late-August order setting a sanctions hearing said she was considering up to $5,000. The sanction order, issued on Friday 11 September 2026, found that the associate failed without good cause to comply with state rules of civil procedure and set the amount at $999.99, one cent below the $1,000 level at which California law requires a court to notify the State Bar. The judge considered the associate's apology, the associate's statement of having attended an AI legal ethics class, and the new practices on the ethical use of AI that counsel had instituted. State Farm said it expects its outside counsel to meet the highest ethical standards, including in their use of AI.

Reported harm

According to Law360's report of the order, the associate who filed the AI-assisted motions was sanctioned $999.99; the associate's declaration apologised for the time and resources the court, the plaintiff and the attorneys spent on the false citations.

Outcome

Resolved

Order of Judge Elizabeth L. Bradley, Los Angeles County Superior Court (reported by Law360 on 14 September 2026 as issued the previous Friday): $999.99 sanction against the associate for failing, without good cause, to comply with state rules of civil procedure. The judge's late-August order setting the hearing had said she was considering up to $5,000. The order itself was not inspected.

What remains unknown

  • The text of the sanction order (not inspected; known through Law360).
  • Which citations Irys generated and which the associate wrote; the sources give only the totals.
  • Whether the false citations affected any ruling on the motions in limine; no source says so.
  • Whether the plaintiff incurred costs beyond the time spent identifying the citations; no source quantifies it.

What the evidence supports

AI involvement: supported. The associate's declaration says she used the AI program Irys to prepare the motions and did not check some of the citations included in them; her review found seven non-existent case citations across eight motions, and the firm acknowledged citations that appeared to be AI hallucinations. The program's output reached the associate and went into the filings (communicated_with), and the court sanctioned the associate for them, Law360 reports. The tool's output itself is not reproduced in the inspected sources.

9 claims: 1 corroborated, 8 reported. What the statuses mean

Reported A Los Angeles judge ordered the State Farm attorney who filed several motions citing non-existent cases and fabricated quotations generated by AI software to pay a $999.99 sanction.

Causal attribution. Law360's report of the order; the order itself was not inspected.

  • law360.com(opens in new tab) supports · English
    An attorney for State Farm who filed several motions citing nonexistent cases and fabricated quotes generated by AI software must pay a $999.99 sanction, a Los Angeles judge ruled
Reported In a declaration, the associate who prepared the motions said she used an AI program called Irys to prepare them, did not check some of the citations because she wrongly believed the program was cite-checked through the firm's Westlaw subscription, and confirmed seven case citations across eight motions in limine that did not exist.

Causal attribution. The associate's own declaration (reproduced by Reason and summarised by CalMatters); one origin.

  • reason.com(opens in new tab) supports · English
    To assist in my preparation of these motions, I utilized an Artificial Intelligence program called "Irys." However, I regrettably did not check some of the cites I chose to include in the filed pleadings ... there were seven (7) case citations across State Farm's eight (8) motions in limine that simply did not exist
  • calmatters.org(opens in new tab) supports · English
    used an AI tool called Irys, which she incorrectly thought was tied to her law firm
Corroborated The plaintiff's lawyers found the non-existent citations and raised them with the court at a status conference on 7 August 2026.

Causal attribution. The associate's declaration and the plaintiff side's own filings (as reported by Law360 and CalMatters) agree on the discovery and its date.

  • reason.com(opens in new tab) supports · English
    informed the Court that they had discovered several citations in State Farm's motion in limine filings that were "fabricated" and possibly "hallucinations."
  • law360.com(opens in new tab) supports · English
    were brought to the court's attention during a status hearing on Aug. 7
  • calmatters.org(opens in new tab) supports · English
    shared his findings at an Aug. 7 conference in Los Angeles Superior Court
Reported According to a declaration by one of the plaintiff's lawyers, the filings contained seven made-up cases, nine quotations from orders that did not exist and 13 fabricated holdings or statements of law.

Causal attribution. The plaintiff lawyer's declaration as reported by Law360.

Reported The firm acknowledged citations that appeared to be AI hallucinations, and its lead trial counsel apologised to the court and to the plaintiff, saying his co-counsel told him she had used AI to help prepare some filings.

Causal attribution. The firm's own filings, as reported by the Los Angeles Times and CalMatters.

  • latimes.com(opens in new tab) supports · English
    acknowledged the firm had discovered “nonexistent case citations which appear to have been AI hallucinations” across a recent batch of motions
  • calmatters.org(opens in new tab) supports · English
    apologized to the court and to the plaintiff, explaining that his co-counsel told him she used AI to help prepare some filings
Reported The associate's declaration ties the issue particularly to the first five motions in limine, which the firm filed and served on 31 March 2026.

Causal attribution. The associate's declaration.

  • reason.com(opens in new tab) supports · English
    particularly as it relates to State Farm's first five motions in limine which our office filed and served on March 31, 2026
Reported According to Law360, the judge had said in late August that she was considering a sanction of up to $5,000; the $999.99 set is one cent below the level that requires a California court to notify the State Bar.

Causal attribution. Law360's report of the two orders.

  • law360.com(opens in new tab) supports · English
    The sum falls several thousand dollars below the maximum penalty, $5,000, that Judge Bradley said she was considering when setting the sanctions hearing
Reported State Farm said it expects its outside counsel to meet the highest ethical and professional standards, including in their use of AI and in confirming the accuracy of filings.

Causal attribution. State Farm spokesperson's statement to the Los Angeles Times.

  • latimes.com(opens in new tab) supports · English
    State Farm expects its external counsel to conform to the highest level of ethical standards and professionalism, including in their use of AI and confirming the accuracy of all legal filings
Reported The associate's declaration apologised for the time and resources the court, the plaintiff and the attorneys had to spend on the issue.

Causal attribution. The associate's declaration.

  • reason.com(opens in new tab) supports · English
    I am sincerely apologetic for the inconvenience and waste of time and resources I have forced the Court

Sources

4 sources inspected. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

Read in full on 2026-10-17 (HTTP 200). Published 14 September 2026; reports the sanction order, the late-August order and the plaintiff lawyer's declaration. Applies to s1.

Read on 2026-10-17 (HTTP 200). Published 24 August 2026; reproduces long passages of the associate's declaration and quotes the Los Angeles Times. Applies to s2.

Read on 2026-10-17 through an Internet Archive capture after the live page returned HTTP 429. Published 18 August 2026; reports filings by both sides. Applies to s3.

Read on 2026-10-17 (HTTP 200). Published 19 August 2026. Applies to s4.

Event countries: United States. Affected-person countries: Unknown. Court countries: United States.

The motions were filed in, and the sanction imposed by, Los Angeles County Superior Court in California. Where the associate lives is not used.

Reviewed for publication 2026-10-17: Published as a concrete adverse consequence of AI use: the associate's declaration says the AI program Irys was used to prepare motions that contained seven non-existent case citations, and the court sanctioned the associate $999.99 for them, according to Law360's report of the order.

People described

A senior associate at the outside law firm representing State Farm, who prepared motions with an AI program and was sanctioned for their non-existent citations

People reported harmed in this case

1 person

1 AI participant · 0 other people harmed

One person: the associate the court sanctioned (Law360). The associate's declaration apologises for time and resources that the court, the plaintiff and the attorneys spent on the issue; no further consequence for the plaintiff is described, so the plaintiff is not counted.

Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.

Tags

#united-states#california#legal-profession#hallucinated-citations#court-sanction#insurance-litigation

Cite this case

Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.

APA

NOPE. (2026). Los Angeles judge sanctions State Farm's outside lawyer $999.99 over motions citing non-existent cases; the lawyer said she prepared them with the AI tool Irys. AI incidents. https://nope.net/incidents/2026-los-angeles-court-sanctions-state-farm-outside-lawyer-for-motions-citing-non-existent-cases-from-ai-tool

BibTeX

@misc{2026_los_angeles_court_sanctions_state_farm_outside_lawyer_for_motions_citing_non_existent_cases_from_ai_tool,
  title = {Los Angeles judge sanctions State Farm's outside lawyer \$999.99 over motions citing non-existent cases; the lawyer said she prepared them with the AI tool Irys},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2026-los-angeles-court-sanctions-state-farm-outside-lawyer-for-motions-citing-non-existent-cases-from-ai-tool}
}

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