Sanction teardown · Los Angeles County Superior Court, USA · 2026-08-11
Meni-Silga v. State Farm
What happened
In Los Angeles County Superior Court, USA, a filing relied on Irys to help draft legal argument. The court identified the following problems with the citations in that filing:
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Fabricated (Case Law)Cited a purported California Supreme Court decision involving Pacific Gas & Electric allegedly from 1996; later acknowledged to be nonexistent and AI-generated.
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Fabricated (Case Law)Cited a nonexistent 2021 case brought by the government to argue that an expert cannot be a back channel for inadmissible hearsay; acknowledged as AI hallucination.
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Fabricated (Case Law)Cited an imagined 2014 case involving State Farm to support the insurer's limited liability for home damage; later admitted not to exist and to be AI-generated.
Which AI tool
Irys. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.
Outcome
Outside counsel admitted the errors and apologized to the court; no professional sanctions or monetary penalties reported.
Additional detail
Outside counsel for State Farm used the legal-AI tool Irys to prepare motions and submitted several nonexistent case citations in filings in an insurance dispute arising from a Carson house fire. Opposing counsel Michael Shaolian identified the fabricated authorities; Musick, Peeler & Garrett and attorney Jacquelene Robinson acknowledged the AI-generated errors in an Aug. 11 filing, apologized, and said they failed to fact-check the citations. The court was notified but no disciplinary sanctions or fines were reported; the firm stated it will implement safeguards to prevent recurrence.
How Citation Safe would have caught this
Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.
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Source: https://www.damiencharlotin.com/documents/2904/AI_hallucinated_case_law_in_court_f_x8FNIKM.A._County_fire_dispute_-_Los_Angeles_Times.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).