State Farm AI Hallucinations Cited in Carson Fire Insurance Case

Outside counsel admits AI-generated legal citations were not real

CARSON, California — Attorneys representing State Farm have apologized to a court after filing legal briefs containing fabricated case citations in a dispute over insurance coverage for a Carson home damaged by fire and later rain, according to court filings submitted this month.

The citations were included in motions filed by Musick, Peeler & Garrett, an outside law firm representing State Farm in litigation brought by homeowner Fa’alagilagi Meni-Silga. Meni-Silga sued the insurer in 2024, alleging bad-faith handling of her claim after her home sustained significant damage.

Jacquelene Robinson, an attorney at the firm, accepted responsibility in an Aug. 11 filing after the errors were brought to the court’s attention. She said she had used Irys, a legal artificial intelligence company, while preparing the material but did not verify that the cited authorities actually existed.

“I am deeply apologetic for the above-mentioned submissions and my serious lapse in professional judgment,” Robinson wrote. “As such, I accept responsibility for those inexcusable errors, and offer no excuse, only an apology.”

Fictitious rulings were used to support State Farm’s arguments

The defective filings cited several purported decisions that State Farm’s lawyers later acknowledged were nonexistent. One was described as a 1996 California Supreme Court ruling involving Pacific Gas & Electric and was used to support the argument that insurance claims must be decided on their own facts.

Another supposed 2021 government case was cited in support of an evidentiary argument concerning expert testimony and inadmissible hearsay. The briefs also referred to an apparent 2014 State Farm case in an effort to argue that the insurer was not liable for all damage claimed at the Carson property.

Michael Shaolian, the attorney representing Meni-Silga, identified the problems. After the citations were challenged, Musick, Peeler & Garrett told the court it had found “nonexistent case citations which appear to have been AI hallucinations” in a recent set of motions.

The episode adds to a growing list of legal cases in which attorneys have faced scrutiny, sanctions or court orders after relying on generative AI tools that produced fictional judicial opinions. The incident underscores that lawyers remain responsible for checking authorities submitted to courts, even when AI is used as a research or drafting tool.

Insurer says it is strengthening safeguards

State Farm said it expects the lawyers it retains to meet professional and ethical obligations when using emerging technology. Tom Hartmann, a spokesperson for the insurer, said the company is working to ensure “appropriate safeguards are in place to prevent similar errors in the future.”

“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,” Hartmann said.

The dispute comes as State Farm faces heightened scrutiny in California over its handling of wildfire-related claims. The company uses outside firms in policy litigation, including cases tied to alleged claim-handling failures after the January 2025 wildfires.

In spring 2026, the California Department of Insurance said it was considering a temporary ban on State Farm writing new policies after receiving complaints from residents affected by the Palisades and Eaton fires. Insurance Commissioner Ricardo Lara said the department found that State Farm had delayed and underpaid policyholders and buried them in red tape. State Farm disputed that assessment and blamed regulatory delays for problems in California’s homeowners insurance market.

The Carson insurance case remains pending, while State Farm and its outside counsel have acknowledged the erroneous citations and said safeguards are being reviewed.