AI Hallucinations in State Farm Insurance Outside Lawyers' Filings

From L.A. Times (Rebecca Ellis) Wednesday:

As part of an insurance dispute over a fire-damaged Carson home, attorneys for State Farm cited several cases in court filings this month that they later acknowledged don’t exist….

“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,” [State Farm spokesman Tom Hartmann] said.

From the State Farm lawyer’s declaration, in Meni-Siliga v. A’s Contractor, Inc. (Cal. Super. Ct. L.A. County):

I submit this declaration to, first and foremost, express my deepest apologies and regret to the Court, Ms. Siliga and her attorneys. I also submit this declaration to outline the steps our office has taken to determine the scope of these issues within State Farm’s Motions in Limine or other filings. As set forth below, I have reviewed all of State Farm’s Motions in Limine and supporting reply briefs, State Farm’s Oppositions to Plaintiff’s Motions in Limine, and, as a precaution, all pleadings in connection with State Farm’s Motion for Summary Judgment/Adjudication and Plaintiff’s Motion for Reconsideration. Based on that review, I can represent that there are no AI hallucinations within any of State Farm’s Oppositions, Replies or the MSJ documents.

At the close of the most recent Final Status Conference on Friday, August 7, 2026, counsel for Plaintiff – Eric M. Khodadian, Esq. with Cummins & White LLP and Michael Shaolian, Esq. with The Shaolian Law Firm P.C. – informed the Court that they had discovered several citations in State Farm’s motion in limine filings that were “fabricated” and possibly “hallucinations.” This was the first time I became aware of the issue with prior filings, particularly as it relates to State Farm’s first five motions in limine which our office filed and served on March 31, 2026. The issues had not been raised with us prior to or after the first two [Final Status Conferences] or before the end of the August 7th hearing….

Because of the seriousness of the allegations and the importance to [my colleague and State Farm's lead counsel], myself, our firm and State Farm of ensuring the integrity of any of our filings submitted to the Court in this matter and others, I began an investigation of the matter immediately upon my return from the August 7, 2026, Final Status Conference. With sincerest regret, I unfortunately discovered that Mr. Khodadian and Mr. Shaolian were correct, and that there were seven (7) case citations across State Farm’s eight (8) motions in limine that simply did not exist. These include the following citations [details omitted -EV]….

As an officer of the Court with great respect for the Court and counsel and committed to the integrity of my legal, factual and ethical representations to and interactions with the same, 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.

As second-chair trial counsel for State Farm in this matter, I was the person primarily responsible for the preparation of the motions in limine discussed above. 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, and I believed, incorrectly, that the program was tied to and vetted through our firm’s subscription to the Westlaw legal research tool and performed an internal cite check. Unfortunately, I was mistaken and only learned of that mistake when I went back to do the research identified in Paragraph 3 above. Regardless, I acknowledge and agree that I should have, but neglected to perform a cite check on all of the authorities cited in the motions in limine discussed above before they were filed with the Court and provided to counsel.

To do our best to immediately correct this mistake and make sure it did not impact any other pleadings, I have now re-reviewed our motion for summary judgment papers (including our moving and reply papers), our opposition to the motion for reconsideration (which was prepared with no AI assistance) and our in limine filings (some of which were prepared with AI assistance). Only some of the in limine filings were affected. Based on my thorough review of those filings (which I reviewed twice), the affected in limine filings are identified above in Paragraph 5 of this Declaration. No reply briefs nor oppositions were affected.

With respect to the affected in limine filings, our office is concurrently filing, without comment, redlined copies to identify and advise the Court of the improper citations and allow it to assess their impact.

Once again, I am sincerely apologetic for the inconvenience and waste of time and resources I have forced the Court, Ms. Siliga and attorneys to expend on this issue that should never have arisen.

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