State Farm lawyer admits AI-generated bogus case citations in court filings

In the dispute over a fire-damaged residence in Carson, plaintiff lawyers discovered that State Farm’s motions in limine contained seven citations to cases that do not exist. The insurer’s second-chair trial counsel, who prepared the motions, admitted using an artificial-intelligence program named Irys and mistakenly believing it was integrated with Westlaw’s citation verification. After the court’s final status conference on August 7, 2026, he filed a declaration apologizing for the oversight, confirming that only the eight motions in limine were affected and that reply briefs and oppositions were clean.

The lawyer said the firm is submitting redlined versions of the flawed filings without comment for the court’s review. State Farm spokesman Tom Hartmann reiterated the company’s expectation that external counsel uphold the highest ethical standards, including accurate AI usage. The incident highlights the risks of relying on AI tools without independent verification in legal practice.