From the Los Angeles Times, by Rebecca Ellis, on a Wednesday:
In connection with an insurance dispute over a house in Carson damaged by fire, State Farm’s lawyers cited a number of authorities in filings this month that they later admitted do not exist….
“State Farm expects its external counsel to adhere to the highest standards of ethics and professionalism, including in their use of AI and in verifying the accuracy of every legal filing,” said State Farm spokesman Tom Hartmann.
From the statement of State Farm’s attorney, in Meni-Siliga v. A’s Contractor, Inc. (Cal. Super. Ct. L.A. County):
I submit this declaration to first and foremost offer my deepest apologies and regrets to the Court, to Ms. Siliga, and to 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 detailed below, I have reviewed all of State Farm’s Motions in Limine and the accompanying reply briefs, State Farm’s Oppositions to Plaintiff’s Motions in Limine, and, as a precaution, all pleadings related to State Farm’s Motion for Summary Judgment/Adjudication and Plaintiff’s Motion for Reconsideration. Based on that review, I can state that there are no AI hallucinations present in any of State Farm’s Oppositions, Replies, or the MSJ documents.
At the conclusion of the most recent Final Status Conference on Friday, August 7, 2026, counsel for the 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 found several citations in State Farm’s motion in limine filings that were “fabricated” and possibly “hallucinations.” This was the first instance I became aware of the issue concerning earlier filings, particularly with regard 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 close of the August 7th hearing….
Because of the gravity of the allegations and the importance to [my colleague and State Farm’s lead counsel], as well as to our firm and State Farm in ensuring the integrity of any filings submitted to the Court in this matter and others, I began an investigation of the matter immediately upon returning from the August 7, 2026 Final Status Conference. With the utmost regret, I discovered that Mr. Khodadian and Mr. Shaolian were correct, and that seven (7) case citations across State Farm’s eight (8) motions in limine did not exist. These include the citations described below [details omitted -EV]….
As an officer of the Court who holds the Court and counsel in high esteem and who is committed to the integrity of my legal, factual, and ethical representations and interactions with them, I am profoundly sorry for the submissions cited above and for the serious lapse in my professional judgment. Accordingly, I accept responsibility for those inexcusable errors, offering no excuse—only an apology.
As the State Farm trial counsel serving as the second chair in this matter, I was primarily responsible for preparing the in limine motions discussed above. To aid in preparing these motions, I used an Artificial Intelligence program called “Irys.” Regrettably, I did not verify some of the citations I included in the filed pleadings, and I incorrectly believed that the program was linked to and vetted through our firm’s subscription to the Westlaw legal research tool and would conduct an internal cite check. Unfortunately, I was mistaken and only learned of that error when I revisited the research described in Paragraph 3 above. Regardless, I acknowledge and agree that I should have, but failed to, perform a cite check on all authorities cited in the in limine motions discussed above before they were filed with the Court and provided to counsel.
To rectify the situation as promptly as possible and ensure it did not affect any other pleadings, I have now re-examined our summary judgment papers (including the moving and reply briefs), our opposition to the motion for reconsideration (which was prepared without AI assistance) and our in limine filings (some of which were prepared with AI assistance). Only a portion of the in limine filings were impacted. Based on my thorough review of those filings (completed 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 submitting, without comment, redlined copies to identify and inform the Court of the improper citations and to allow it to gauge their impact.
Again, I extend my sincere apologies for the inconvenience and the wasted time and resources that I have imposed on the Court, Ms. Siliga, and the attorneys involved in this matter, which never should have occurred.
