Meni-Siliga v. A's Contractor Inc. et al.
The case
Meni-Siliga v. State Farm General Insurance Co., Los Angeles Superior Court, sanctions order entered Friday, September 11, 2026 (Judge Elizabeth L. Bradley). Reported: https://www.reuters.com/legal/litigation/lawyer-state-farm-fined-over-ai-hallucination-los-angeles-lawsuit-2026-09-14/ ; https://www.lawcommentary.com/articles/state-farm-lawyer-ai-fake-cases-fine
What happened
Jacquelene Robinson, a senior associate at Musick, Peeler & Garrett representing State Farm General Insurance Company, prepared pretrial filings (motions in limine, ahead of an October 5 trial) using Irys, an AI legal-research tool. Robinson believed Irys was connected to her firm's Westlaw subscription and believed the tool performed an internal citation check. The filings contained seven case citations that did not exist, plus incorrect case names and quotations that could not be found in the authorities cited. The problem was pervasive: plaintiff's counsel Eric Khodadian told the court the fake authorities appeared in "nearly every single motion in limine filed by State Farm in this case." The errors surfaced at an August 7 court conference; Robinson then reviewed the filings and confirmed the seven cases did not exist. She acknowledged she "relied on the tool without independently verifying every authority before the documents were filed." In a declaration before the sanctions hearing she apologized, took full responsibility, and said she had changed her research process (retrieve cited decisions through Westlaw, LexisNexis or another reliable source; check quotations against the underlying opinions; conduct a pre-filing citation review; independently verify AI-generated authorities). The underlying suit is a 2024 homeowner coverage action by Fa'alagilagi Meni-Siliga over a 2020 fire and later storm damage at a home in Carson, California.
The rule and the sanction
Judge Bradley imposed a $999.99 fine on Robinson. The figure sits one cent below California's $1,000 threshold that generally requires a court to notify the State Bar of a judicial sanction, whether the precise penny was deliberate, the sources do not say. No State Bar referral was reported. State Farm, in a statement, said it "expects all external counsel to adhere to the highest standards of professionalism and ethical conduct, including when using AI and when reviewing and confirming the accuracy of all court filings," and said it was working with outside counsel to put safeguards in place.
How it could have been avoided
"My research tool has its own citation check" is not verification: an AI product's internal QA is part of the same unverified pipeline, and Robinson's belief that Irys was connected to Westlaw made its output more trusted, not more checked. Retrieve every cited decision through an independent source (Westlaw, Lexis, or another reliable database) and check every quotation against the underlying opinion before filing. Pervasiveness compounds the problem: one bad citation reads as a mistake, but fake citations in nearly every pretrial motion reads as a practice, and it was opposing counsel who caught it, not the filer. And don't file first and audit later: Robinson's confirmation that seven cases didn't exist came after the filings were already before the court.
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Backfill, September 17, 2026. Entries D-58 through D-166 were added in a systematic backfill that reconciled this library against legal researcher Damien Charlotin's AI-hallucination database and other trackers. Each entry was verified against its primary court document before inclusion; candidates whose primary documents did not establish generative-AI misuse or a Tier 1/2 sanction were rejected. Two follow-on developments were annotated into D-35 and D-54 instead of receiving new entries. Full added/rejected/duplicate log: `~/workspace/goals/ai-sanctions-case-monitoring/hidden_files/backfill-log-2026-09-17.md`.