Los Angeles County Judge Elizabeth L. Bradley hit Jacquelene A. Robinson, a senior associate at Musick Peeler & Garrett LLP, with the sanction on Friday after the attorney inserted AI hallucinations across five motions on behalf of State Farm. The judge's order found that Robinson failed, without good cause, to comply with state rules of civil procedure.
The sum falls several thousand dollars below the maximum penalty, $5,000, that Judge Bradley said she was considering when setting the sanctions hearing, according to an order issued in late August. And, most notably, the sum was one cent below the threshold established in California state law that requires a court to notify the state bar when it imposes "any judicial sanctions on an attorney of $1,000 or more, except sanctions for failure to make discovery," according to the state statute.
When coming to the specific number, the order says, Judge Bradley considered Robinson's apology, the attorney's claim that she attended an AI legal ethics class and the "new practices counsel has instituted regarding the ethical use of AI."
In August, attorneys from Musick Peeler admitted and apologized for including the hallucinations, which appeared in motions that sought to exclude certain evidence from an impending trial.
The AI hallucinations were discovered by the plaintiff's counsel, Michael Shaolian of the Shaolian Law Firm PC, and were brought to the court's attention during a status hearing on Aug. 7. At the time, he had discovered seven made-up cases, nine quotes for orders that did not exist and 13 "fabricated holdings/statements of law," he said in a declaration.
Robinson told the court she had used an AI program called Irys to aid her when writing the motions at issue. This appears to be the legal research tool that was built by Iqidis Inc. and markets itself as an AI platform "built by lawyers," according to the company's website.
The underlying litigation was filed by California homeowner Fa'alagilagi Meni-Siliga in 2024 against State Farm Insurance and others. It claimed that they botched the repair of her fire-damaged home, failed to report a subsequent rainstorm that caused additional destruction, and left her property in such disrepair that she ultimately lost it to foreclosure.
Robinson's apology to the court noted that she attended a class on Aug. 20 hosted by Thomson Reuters titled "Beyond the Hype: Practical AI Ethics for Legal Practitioners." Additionally, her apology said she was "deeply remorseful that this occurred" and asked that no monetary sanctions be imposed.
Counsel for the plaintiff and State Farm did not immediately respond to a request for comment Monday.
Meni-Siliga is represented by Eric M. Khodadian of Cummins & White LLP, and by Michael Shaolian of Shaolian Law Firm PC.
State Farm is represented by Steven J. Elie, Kenneth G. Katel and Jacquelene A. Robinson of Musick Peeler & Garrett LLP.
The case is Meni-Siliga v. A's Contractor Inc. et al., case number 24CMCV01105, in Los Angeles County Superior Court.
--Editing by Karin Roberts.
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