$31,000 sanction for AI-generated false citations in Lacey v. State Farm brief
A Special Master in a California federal court sanctioned two law firms $31,000 for submitting a brief containing approximately nine false legal citations and fabricated quotations generated by AI tools. An attorney at Ellis George created an AI-generated outline that was incorporated into the brief by K&L Gates without verification, and the firms failed to catch the errors even after the Special Master initially flagged two incorrect citations.
What happened
An attorney at Ellis George Cipolla LLP used various AI tools to generate an outline for a supplemental brief in a discovery dispute in Lacey v. State Farm. The outline was passed to K&L Gates LLP, which incorporated it into the brief submitted to the Special Master without verification.
The brief contained approximately nine false, inaccurate, or misleading legal citations out of 27 total. At least two cited authorities did not exist, and several quotations were fabricated. The Special Master initially identified two erroneous citations and requested correction; the firms resubmitted the brief, but it retained AI-generated errors.
Reported impact
The Special Master issued orders on April 15 and 20 regarding the false citations and imposed sanctions combining litigation sanctions against the plaintiff and financial payments from the lawyers and law firms totaling $31,000.
Index analysis
The lawyers' declarations revealed that the source of the errors was inappropriate use of and reliance on AI tools. The attorney at Ellis George who created the outline candidly admitted responsibility and expressed remorse; K&L Gates attorneys were unaware the outline contained AI-generated research.
Governance controls
The court noted that both firms have excellent reputations and that this error is not characteristic of their work. The Special Master concluded that additional financial or disciplinary sanctions against the individual attorneys were not warranted, as the matter was properly resolved through the combined sanctions.
Classification
Sources and evidence
This record was researched and written by the Index, based on the following original reporting.