{"meta":{"exportedAt":"2026-10-17T08:19:52.810Z","formatVersion":2,"selection":{"q":"insurance-litigation","system":"","harm":"","context":"","country":"","role":"","relation":"","evidence":"","year":"","response":"regulatory","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":1,"coverage":{"cases":1,"countries":1,"languages":1,"unknownLocation":0,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":1,"minors":0,"coreRelations":1,"contextualRelations":0,"mixedRelations":0,"unknownRelations":0,"relationPending":0,"relationUnknown":0},"countingNote":"Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.","affectedCountNote":"Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.","source":"AI incidents","publisher":"NOPE","url":"https://nope.net/incidents","license":"CC BY 4.0"},"incidents":[{"id":"2026-los-angeles-court-sanctions-state-farm-outside-lawyer-for-motions-citing-non-existent-cases-from-ai-tool","caseFacts":{"claims":[{"id":"c1","status":"reported","evidence":[{"locator":"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","relation":"supports","source_id":"s1"}],"assertion":"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."},{"id":"c2","status":"reported","evidence":[{"locator":"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","relation":"supports","source_id":"s2"},{"locator":"used an AI tool called Irys, which she incorrectly thought was tied to her law firm","relation":"supports","source_id":"s3"}],"assertion":"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."},{"id":"c3","status":"corroborated","evidence":[{"locator":"informed the Court that they had discovered several citations in State Farm's motion in limine filings that were \"fabricated\" and possibly \"hallucinations.\"","relation":"supports","source_id":"s2"},{"locator":"were brought to the court's attention during a status hearing on Aug. 7","relation":"supports","source_id":"s1"},{"locator":"shared his findings at an Aug. 7 conference in Los Angeles Superior Court","relation":"supports","source_id":"s3"}],"assertion":"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."},{"id":"c4","status":"reported","evidence":[{"locator":"he had discovered seven made-up cases, nine quotes for orders that did not exist and 13","relation":"supports","source_id":"s1"}],"assertion":"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."},{"id":"c5","status":"reported","evidence":[{"locator":"acknowledged the firm had discovered “nonexistent case citations which appear to have been AI hallucinations” across a recent batch of motions","relation":"supports","source_id":"s4"},{"locator":"apologized to the court and to the plaintiff, explaining that his co-counsel told him she used AI to help prepare some filings","relation":"supports","source_id":"s3"}],"assertion":"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."},{"id":"c6","status":"reported","evidence":[{"locator":"particularly as it relates to State Farm's first five motions in limine which our office filed and served on March 31, 2026","relation":"supports","source_id":"s2"}],"assertion":"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."},{"id":"c7","status":"reported","evidence":[{"locator":"The sum falls several thousand dollars below the maximum penalty, $5,000, that Judge Bradley said she was considering when setting the sanctions hearing","relation":"supports","source_id":"s1"}],"assertion":"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."},{"id":"c8","status":"reported","evidence":[{"locator":"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","relation":"supports","source_id":"s4"}],"assertion":"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."},{"id":"c9","status":"reported","evidence":[{"locator":"I am sincerely apologetic for the inconvenience and waste of time and resources I have forced the Court","relation":"supports","source_id":"s2"}],"assertion":"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."}],"effects":[{"label":"sanctioned $999.99 for motions with non-existent citations prepared with an AI program","claim_id":"c1","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.law360.com/articles/2524716/state-farm-attorney-sanctioned-999-99-for-ai-hallucinations","kind":"news","access":"read","language":"en","translation_note":"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.","independence_group":"law360-report-of-sanction-order-september-2026"},{"id":"s2","url":"https://reason.com/volokh/2026/08/24/ai-hallucinations-in-state-farm-insurance-outside-lawyers-filings/","kind":"commentary_with_filing_excerpt","access":"read","language":"en","translation_note":"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.","independence_group":"state-farm-associate-declaration-august-2026"},{"id":"s3","url":"https://calmatters.org/economy/2026/08/state-farm-lawsuit-ai-hallucinations/","kind":"news","access":"read","language":"en","translation_note":"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.","independence_group":"calmatters-filings-report-august-2026"},{"id":"s4","url":"https://www.latimes.com/california/story/2026-08-19/ai-hallucinations-case-law-state-farm-la-county-fire-dispute","kind":"news","access":"read","language":"en","translation_note":"Read on 2026-10-17 (HTTP 200). Published 19 August 2026.","independence_group":"los-angeles-times-report-august-2026"}],"version":1,"ai_roles":["own_use"],"contexts":["justice","work"],"unknowns":["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."],"geography":{"basis":"The motions were filed in, and the sanction imposed by, Los Angeles County Superior Court in California. Where the associate lives is not used.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"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.","reviewed_on":"2026-10-17"},"ai_involvement":{"basis":"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.","status":"supported"},"person_relations":["communicated_with"]},"name":"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","summary":"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.","incidentDate":"2026-03-31","incidentEndDate":"2026-09-11","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2026-08-18","aiSystem":"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.","aiProduct":"Irys (reported)","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["financial_loss","legal_harm"],"harmOutcomeSummary":"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.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"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.","victimAgeRange":"adult","jurisdiction":"US-CA","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://www.law360.com/articles/2524716/state-farm-attorney-sanctioned-999-99-for-ai-hallucinations","primarySourceLabel":"Law360, State Farm Attorney Sanctioned $999.99 For AI Hallucinations (14 September 2026)","firstPublishedAt":"2026-10-17T03:02:07.57541+00:00","updatedAt":"2026-10-17T03:02:07.57541+00:00","scopeVersion":"facts-v3","tags":["united-states","california","legal-profession","hallucinated-citations","court-sanction","insurance-litigation"]}]}