VERITAS
May 6, 2025 · AI sanctions database

Lacey v. State Farm General Insurance

Lacey v. State Farm General Insurance is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court
C.D. Cal
Date
May 6, 2025
Party
Lawyer
AI tool
Google Gemini
Outcome
Non-monetary sanctions plus $31,100 monetary compensation ordered against plaintiff's law firms (joint and several); briefs stricken
Penalty
$31,100 in monetary penalties.
FineProfessional sanction

What the record shows

The Special Master found that plaintiff's counsel, at two firms, submitted briefs containing AI-generated citations to authorities that do not exist, including quoted text the Special Master confirmed does not appear in the cited National Steel Products opinion. Declining to sanction the individual lawyers in light of their full admissions and apologies, the Special Master struck the supplemental briefs and ordered the firms, jointly and severally, to pay the defense $31,100 in compensation. Counsel declarations attributed the bad citations to tools including CoCounsel, Westlaw Precision, and Google Gemini.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · C.D. Cal