State Farm lawyers submit AI-generated fake case citations in Carson fire insurance dispute
State Farm's outside counsel submitted court motions in a California insurance dispute containing multiple AI-generated fake case citations from the legal AI tool Irys, without fact-checking. The filings were discovered to contain nonexistent cases cited to support the insurer's arguments, prompting a public apology from the responsible attorney.
What happened
Attorneys for State Farm, represented by outside counsel Musick, Peeler & Garrett, submitted court motions in an insurance dispute over a fire-damaged home in Carson, Los Angeles County, that contained multiple nonexistent case citations. The filings cited a purported 1996 California Supreme Court decision involving Pacific Gas & Electric, a nonexistent 2021 government case, and an imagined 2014 case involving State Farm. The attorneys used legal AI company Irys to generate research for the motions but did not fact-check the filings.
Reported impact
The homeowner, Fa'alagilagi Meni-Siliga, had her home rendered uninhabitable by a 2020 fire in Carson and experienced further complications including water damage from a storm during repairs, delays in obtaining State Farm approval, bankruptcy, and loss of her home to foreclosure. Attorney Michael Shaolian, representing the homeowner, discovered the fabricated citations during case proceedings.
Index analysis
The use of AI-generated legal research without adequate fact-checking created false precedents intended to support State Farm's arguments that insurance claims must be adjudicated individually, that expert testimony cannot serve as a channel for inadmissible hearsay, and that State Farm was not responsible for covering all damage to the plaintiff's home.
Governance controls
Attorney Jacquelene Robinson of Musick, Peeler & Garrett issued a public apology on August 11, 2026, stating: "I am deeply apologetic for the above-mentioned submissions and my serious lapse in professional judgment. As such, I accept responsibility for those inexcusable errors, and offer no excuse, only an apology."
Classification
Sources and evidence
This record was researched and written by the Index, based on the following original reporting.