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United StatesProfessional services2025

K&L Gates and Ellis George

Supplemental brief built on AI-drafted research (Lacey v State Farm)

Special master orders two law firms to pay $31,100 over a brief with bogus AI citations and strikes the brief

StoppedRegulator, audit or court

Problem

A ten-page supplemental brief in an insurance dispute had about nine wrong citations out of 27, and at least two cases did not exist. When the special master flagged them, the firms filed a revised brief that still contained errors.

Approach

Special Master Michael Wilner sanctioned K&L Gates and Ellis George jointly. They were ordered to pay about $26,100 in special master fees and $5,000 toward the defense's costs. The order says the lead lawyer used AI tools for an outline that K&L Gates then used without a cite check.

Results

$31,100Total awarded: about $26,100 in special master fees plus $5,000 toward defense costsRegulator, audit or court[1]
9 of 27Citations in the supplemental brief that were wrong in some way, with at least two cases non-existentRegulator, audit or court[1]

Takeaway

The larger firm was sanctioned along with the smaller one because it filed work it had not checked. Re-filing a corrected brief that still has errors made the order harsher.

Categories

Innovation type
Process innovation
AI technology
Generative AI
Evidence
Regulator, audit or court

Sources

Source summaries

[1]The Volokh Conspiracy (Reason)14 May 2025

The special master ordered the firms to pay about $26,100 in fees and $5,000 toward defense costs over the AI-drafted brief. About nine of its 27 citations were wrong, including at least two non-existent cases.

Full details are in the original sources.

Added 25 Oct 2026 · Updated 25 Oct 2026
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