A California judge has fined a State Farm lawyer $999.99 after finding she submitted court filings that cited nonexistent cases generated by an artificial intelligence program. The order highlights the growing risk of AI "hallucinations" in legal work, where fabricated citations can undermine a case and trigger professional sanctions.
The fabricated citations
Judge Elizabeth Bradley of Los Angeles Superior Court issued the sanction on Friday against Jacquelene Robinson, an attorney with the firm Musick, Peeler & Garrett. Robinson's submissions in an insurance coverage dispute included seven case citations that did not exist. The underlying lawsuit, filed in 2024, concerns fire and storm damage at a house in Carson, California. State Farm is a defendant and has denied any wrongdoing.
Lawyers for the plaintiff first spotted the errors. Eric Khodadian, an attorney representing the plaintiff, told the court the problem ran deep. "The issue is pervasive and present in nearly every single motion in limine filed by State Farm in this case," he said.
The lawyer's response
Robinson did not immediately respond to a request for comment. In a court filing, she apologized and said she took full responsibility. "I recognize that citation to fabricated authorities, especially those included in submissions to the court, is unacceptable," Robinson said.
State Farm issued a statement on Monday saying 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."
A pattern across the profession
This case is not isolated. State and federal judges have sanctioned lawyers in dozens of cases where AI programs invented citations, misquoted the law, or fabricated witness testimony. The pressure to use AI tools for efficiency in document review and legal research continues to grow, but the technology's tendency to produce convincing falsehoods demands rigorous verification.
For legal professionals navigating the integration of AI into their workflows, understanding these risks is essential. Resources like AI for Legal offer guidance on responsible adoption, while structured programs such as the AI Learning Path for Paralegals focus on building the verification habits that prevent exactly this kind of error.
Why this matters for legal professionals
The sanction is a direct reminder that the duty of candor to the tribunal rests solely on the attorney, not the software. When AI generates a case citation, every name, volume number, and page reference must be checked against primary sources before filing. A $999.99 fine may seem modest, but the reputational damage and potential malpractice exposure from citing fake law can end careers. The rule is simple: if you cannot find the case in a reporter, do not cite it.
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