State Farm's Outside Lawyers Admit AI Invented Seven Court Citations in Fire-Damage Lawsuit

State Farm's own outside lawyers got caught citing court cases that don't exist. Not sloppy paraphrasing. Not a stretched interpretation. Cases that were never decided, quotes that were never written, holdings that were never issued.

The case is Meni-Siliga v. A's Contractor, Inc., pending in Los Angeles County Superior Court. Fa'alagilagi Meni-Siliga, a U.S. Postal Service carrier, sued her contractor, a public adjuster, and State Farm in July 2024 after a 2020 fire left her Carson home uninhabitable and a subsequent storm caused additional water damage while repairs were underway, according to CalMatters. She says she and her husband drained their savings, filed for bankruptcy, and lost the house to foreclosure while State Farm dragged its feet on approvals.

At an August 7, 2026 Final Status Conference, Meni-Siliga's attorneys, Eric Khodadian of Cummins & White LLP and Michael Shaolian of The Shaolian Law Firm, told the court they'd found citations in State Farm's motions in limine that were "fabricated" and possibly AI hallucinations, according to the L.A. Times. Khodadian later wrote that a State Farm lawyer was "visibly enraged" and followed him down the hallway afterward, "repeatedly demanding to see the list" of errors, according to CalMatters.

State Farm's own legal team went and checked. They shouldn't have liked what they found.

Seven fake citations, eight motions

Jacquelene Robinson, an attorney with Musick, Peeler & Garrett, filed a declaration acknowledging seven case citations across State Farm's eight motions in limine "simply did not exist," per the L.A. Times. Those motions were filed and served back on March 31, 2026, months before anyone caught the problem.

Among the invented material: a supposed 1996 California Supreme Court decision involving Pacific Gas & Electric, cited to argue every insurance claim must be judged on its own facts. A fictional 2021 government case, used to argue an expert witness can't smuggle in hearsay. And a made-up 2014 case involving State Farm itself, cited to argue the company wasn't responsible for covering all the home's damage, according to the L.A. Times.

Robinson said she used an AI tool called Irys, mistakenly believing it was tied to the firm's Westlaw subscription and had run an internal citation check, according to Business Insurance. It hadn't. Nobody verified the citations before they went to a judge.

"I am deeply apologetic for the above-mentioned submissions and my serious lapse in professional judgment," Robinson wrote in an August 11 filing, according to the L.A. Times. "As such, I accept responsibility for those inexcusable errors, and offer no excuse, only an apology."

She reviewed all of State Farm's filings in the case afterward and represented to the court that no other hallucinations turned up in State Farm's oppositions, replies, or summary judgment briefing, according to Reason's coverage of the underlying declaration.

State Farm's response

State Farm spokesman Tom Hartmann said the company expects its outside 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," according to the L.A. Times. The insurer is reviewing what happened and says it's working to put safeguards in place, per Business Insurance.

State Farm didn't write these briefs. Its outside firm did. But the company still put its name on filings nobody verified in a case tied to its handling of a homeowner's claim. Musick, Peeler & Garrett's lead trial counsel told the court he hadn't known AI was used in the filings but accepted responsibility anyway, and the firm says it has since updated its internal AI policy, according to Business Insurance.

Legal hallucinations are becoming more common

A database tracking legal AI hallucinations worldwide, maintained by a Paris-based researcher, has logged 1,922 cases so far, most of them in the United States, according to CalMatters. Stanford law professor Daniel Ho, who has studied the problem, told CalMatters that legal hallucinations are becoming more common as the profession leans on generative AI. A survey cited by CalMatters found 41% of law firms and 47% of corporate legal departments are already using generative AI tools.

Last year, a California attorney was fined a record $10,000 after filing an opening brief with 21 fabricated quotes out of 23 total, according to CalMatters. That penalty didn't stop this one.

The Property Insurance Coverage Law Blog made a fair distinction worth keeping: AI itself isn't the villain here. The blog noted a separate case where AI reasoning models flagged a coverage issue human researchers had missed, and the researchers checked the work and improved their analysis. The difference in the State Farm case wasn't the software. It was that nobody checked it before it went to a judge.

What's unresolved

The Meni-Siliga case is set to go to trial in October, according to CalMatters. It's unclear whether the fabricated citations will affect any rulings already made on the motions in limine, or whether the court will impose sanctions against Musick, Peeler & Garrett beyond the firm's own apology. It's also unclear how many other pending filings by outside counsel for State Farm, or any other insurer, might contain the same kind of unverified AI output that simply hasn't been caught yet.