Incident Tracker / United States (federal)
Lacey v. State Farm General Insurance Co., No. 2:24-cv-05205-FMO-MAA (C.D. Cal.), Order of Special Master (Ellis George LLP and K&L Gates LLP)
·US District Court, Central District of California (Special Master Michael R. Wilner, US Magistrate Judge, ret.)·US-FEDSanctions
In the Central District of California, Special Master Michael Wilner found that Ellis George and K&L Gates lawyers acted in a manner tantamount to bad faith by filing, then re-filing, a privilege brief built on undisclosed AI research with fabricated citations. He struck the briefs, denied the discovery relief sought and ordered the firms to pay $31,100.
- Analysis
- Ellis George and K&L Gates: the $31,100 AI-research sanction, and the re-filing that made it worse
- Court
- US District Court, Central District of California (Special Master Michael R. Wilner, US Magistrate Judge, ret.)
- Date
- 2025-05-06
- Who used the AI
- Lawyer
- AI tool
- CoCounsel, Westlaw Precision and Google Gemini (per counsel's sworn declaration)
- Conduct
- A ten-page supplemental brief on privilege contained about nine incorrect citations out of 27, including at least two authorities that do not exist and quotations attributed to the cited opinions that were not in them. An Ellis George partner generated the research outline with AI tools; K&L Gates lawyers incorporated it without cite-checking. After the Special Master queried two citations, K&L Gates re-filed the brief with the two removed but the other AI errors intact and without disclosing AI use.
- Outcome
- Sanctions
- Penalty
- US$31,100
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-04
Primary sources for this incident
- Order of Special Master Imposing Non-Monetary Sanctions and Awarding Costs, ECF 119 (signed 5 May 2025, filed 6 May 2025), via CourtListener RECAP
- Docket, Lacey v. State Farm General Insurance Co., 2:24-cv-05205 (C.D. Cal.), CourtListener
- Defendant's Rule 11 motion for sanctions, ECF 107 (22 April 2025)
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Lacey v. State Farm General Insurance Co., No. 2:24-cv-05205-FMO-MAA (C.D. Cal.), Order of Special Master (Ellis George LLP and K&L Gates LLP)”, safelegalai.com/tracker/lacey-v-state-farm (accessed 2026-09-05). Data: CC BY 4.0.