State Farm's Outside Counsel Filed Seven Nonexistent Case Citations Across Eight Motions, Believing the AI Tool Had Already Verified Them
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Source: chatgptdisaster.com ↗
She believed Irys was tied to the firm's existing Westlaw subscription, and that it therefore performed an internal cite check as part of what it produced.
Jacquelene Robinson, a senior associate at Musick, Peeler & Garrett representing State Farm in a Los Angeles wildfire case, filed eight motions in limine in March 2026 containing seven citations to cases that do not exist. The citations sat in the court file for five months. Opposing counsel caught them at the Final Status Conference on August 7. Robinson's declaration did not claim a clerical error. She named the tool — a legal research product called Irys — and explained that she believed it was bundled with her firm's Westlaw subscription and that Westlaw had run the cite check. Under that belief, running a separate citator would have been redundancy, not diligence.
That is what makes this case different from the standard AI-citation story. Robinson was not using a general-purpose chatbot; she was using a product positioned inside a professional legal workflow, with an interface that gave her no indication its citations had not been verified against a real database. The plaintiff asked the court to deny the affected motions and issue an order to show cause on sanctions. As of September 5, 2026, no sanction had been reported.