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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 95/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Lacey v. State Farm General Insurance
C.D. California · May 6, 2025
CA / federalEditorial impact: highfake citationsfabricated quotescontracttrial
Direct answer
What happened in this matter?
Fabricated: Case Law | Plaintiff cited a nonexistent case to support bad-faith discovery: Booth v. Allstate Ins. Co.; the Special Master could not locate it and it was later removed. Outcome: Striking of briefs; denial of requested discovery relief; Large monetary sanctions jointly and severally against the two law firms.
- Why the court cared
- The submission and re-submission of AI-generated material without verification, especially after warning signs were raised, was deemed reckless and improper. The court emphasized that undisclosed AI use that results in fabricated law undermines judicial integrity. While individual attorneys were spared, the firms were sanctioned for systemic failure in verification and supervision. The Special Master underscored that the materials nearly made it into a judicial order, calling that prospect “scary” and demanding “strong deterrence.”
- Why it matters now
- Paid tools like CoCounsel and Westlaw AI are not a defense; require a second-attorney verification pass before any AI-assisted brief is filed.
Why this matter is tracked
Fabricated: Case Law | Plaintiff cited a nonexistent case to support bad-faith discovery: Booth v. Allstate Ins. Co.; the Special Master could not locate it and it was later removed. Outcome: Striking of briefs; denial of requested discovery relief; Large monetary sanctions jointly and severally against the two law firms.
AI Use
Counsel used CoCounsel, Westlaw’s AI tools, and Google Gemini to generate a legal outline for a discovery-related supplemental brief. The outline contained hallucinated citations and quotations, which were incorporated into the filed brief by colleagues at both Ellis George and K&L Gates. No one verified the content before filing. After the Special Master flagged two issues, counsel refiled a revised brief—but it still included six AI-generated hallucinations and did not disclose AI use until ordered to respond.
Hallucination Details
At least two cases did not exist at all, including a fabricated quotation attributed to Booth v. Allstate Ins. Co., 198 Cal.App.3d 1357 (1989). Misquoted or fabricated quotes attributed to National Steel Products Co. v. Superior Court, 164 Cal.App.3d 476 (1985). Several additional misquotes and garbled citations across three submitted versions of the brief. Revised versions attempted to silently “fix” errors without disclosing their origin in AI output.
Ruling/Sanction
The Special Master (Judge Wilner) struck all versions of Plaintiff’s supplemental brief, denied the requested discovery relief, and imposed:$26,100 in fees to reimburse Defendant for Special Master costs$5,000 in additional attorney’s fees to DefendantTotal monetary sanction: $31,100, payable jointly and severally by Ellis George LLP and K&L Gates LLPNo sanctions against individual attorneys due to candid admissions and remedial action, but strong warning issued
Key Judicial Reasoning
The submission and re-submission of AI-generated material without verification, especially after warning signs were raised, was deemed reckless and improper. The court emphasized that undisclosed AI use that results in fabricated law undermines judicial integrity. While individual attorneys were spared, the firms were sanctioned for systemic failure in verification and supervision. The Special Master underscored that the materials nearly made it into a judicial order, calling that prospect “scary” and demanding “strong deterrence.”
Operational lesson
Paid tools like CoCounsel and Westlaw AI are not a defense; require a second-attorney verification pass before any AI-assisted brief is filed.
Record details
CaliforniaSingle-state evidence scope
CourtC.D. California
Jurisdictionfederal
Circuit9th Circuit
DateMay 6, 2025
CO
AI toolCoCounsel, Westlaw Precision, Google Gemini
Party typeLawyer
OutcomeStriking of briefs; denial of requested discovery relief; Large monetary sanctions jointly and severally against the two law firms
Known amount$31,100
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
CoCounsel, Westlaw Precision, Google Gemini is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Striking of briefs; denial of requested discovery relief; Large monetary sanctions jointly and severally against the two law firms
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
6 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited a nonexistent case to support bad-faith discovery: Booth v. Allstate Ins. Co.; the Special Master could not locate it and it was later removed.
- False Quotes: Case Law | Plaintiff attributed a fabricated quotation to National Steel Products; the Special Master found the quoted text did not exist in the opinion at the cited pin and the brief was revised.
- Fabricated: Case Law | Plaintiff cited a nonexistent case: Davis v. City of Santa Ana; counsel later admitted it appears not to exist and should be removed.
- False Quotes: Case Law | Plaintiff used a false quotation from Aetna v. Superior Court to assert a sword-and-shield principle; counsel admitted the quote does not appear in that case.
- False Quotes: Case Law | Plaintiff misquoted Lipton v. Superior Court with a sword-and-shield line; counsel acknowledged the quotation was inaccurate.
- False Quotes: Case Law | Plaintiff misquoted and mis-pincited Zurich American Ins. Co. v. Superior Court; counsel admitted the cited language and pin were inaccurate.
Questions this record answers
- What happened in Lacey v. State Farm General Insurance?
- Fabricated: Case Law | Plaintiff cited a nonexistent case to support bad-faith discovery: Booth v. Allstate Ins. Co.; the Special Master could not locate it and it was later removed. Outcome: Striking of briefs; denial of requested discovery relief; Large monetary sanctions jointly and severally against the two law firms.
- Why does Lacey v. State Farm General Insurance matter for legal AI risk?
- Paid tools like CoCounsel and Westlaw AI are not a defense; require a second-attorney verification pass before any AI-assisted brief is filed.
- What does the public record establish about Lacey v. State Farm General Insurance?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Lacey v. State Farm General Insurance summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.