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PAN Lab example

Nevada DETR generative-AI unemployment appeals

The referee who signs: an AI that drafts the ruling

Nevada's unemployment agency had Google build an AI that drafts appeal rulings for referees to sign. This case asks whether signing stays a review.

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Nevada's Department of Employment, Training and Rehabilitation (DETR) contracted Google to build a generative AI, one that writes text, for unemployment appeals. It reads a hearing's transcript and evidence, and searches Nevada law and past appeals decisions. It then drafts a recommended ruling, to approve, deny, or modify the claim, with the written decision, for a referee's review and signature.

How it is meant to be used

Claimants can appeal decisions on their unemployment benefits. Each appeal has a hearing, recorded in a transcript, with evidence. An appeals referee signs the ruling, which is then issued to the claimant. The case file does not define the referee's role further.

Officials presented the AI as a way to clear a backlog of appeals from the pandemic. More than 10,000 appeals were outstanding as of June 2024, with roughly 1,500 pandemic-era claims still pending. The Markup separately reported a drop from more than 40,000 at the pandemic peak to under 5,000.

A referee's determination could take as much as several hours, elsewhere put at about three hours. Officials projected about five minutes per case with the AI. DETR said the required human review adds an estimated 10 to 30 minutes. The five-minute figure leaves that review out.

Who decides

A referee must review and sign each drafted ruling, and DETR says two state workers are involved. The sources do not say whether the referee is one of the two. Director Christopher Sewell said no AI-drafted written decision goes out without human review. He called AI "a great tool" and added, "It's a tool." The signed ruling is then issued to the claimant.

The design's safety rests on that human sign-off. The AI exists to clear a backlog, and the case file argues that a referee who keeps rejecting drafts is then cast as the bottleneck. The drafts carry both the ruling and its reasoning. From outside, a real review and a rubber stamp can look exactly the same.

How accuracy is judged

The contract set a 90 percent success requirement. State workers had to deem the AI's decision correct nine times out of ten on test decisions. The sources do not say what the workers compared each decision against. No independent outside audit checks that grading. DETR said it wanted accuracy above 90 percent before going live.

Critics cite outside studies of legal-research software built by the same method. Those found 17 to 33 percent of answers incorrect and 18 to 63 percent incomplete. The studies did not measure Nevada's AI.

DETR's internal governance committee watches for bias and for hallucinations, content an AI makes up. It meets weekly during fine-tuning, when the AI is adjusted before launch, and quarterly after launch.

Testing, delays, and cost

Rollout was delayed again and again because accuracy in testing fell short. The AI cited incorrect Nevada statutes and failed to pull information from all hearing documents. Officials said those problems were fixed.

In 2024, officials projected a launch within months. As of the latest reporting, in March 2026, the AI was still being tested on past appeals. It was described as launching in the coming weeks. No source confirms it is deciding live claimant appeals.

The reported cost grew over time. It was about 1 million dollars when the Board of Examiners approved the contract in 2024. A later legal analysis put it at roughly 1.38 million. By early 2026 the total price was 2.6 million dollars, with about 1.1 million spent.

Data and consent

The AI runs on Google's Vertex AI Studio cloud platform. DETR says the data stays in the continental United States, and the state holds the encryption keys. It says Google gave assurances it would not access personal information for other purposes.

Claimants are not required to consent to AI processing of their appeal. Reporting says it is unclear whether they are told the AI is involved. No opt-out is described.

What each side says

Legal scholars, attorneys who represent claimants, and a former U.S. Department of Labor official warned that backlog and speed pressure could hollow out the review. They said it could create incentives to rubber-stamp the AI's drafts. One attorney said the time savings "only happens if the review is very cursory." A legal analysis warned that staff "might feel pressured to authorize AI decisions on appeal with haste."

State Sen. Dina Neal said Nevada would be "contracting a Nevada citizen's rights without their consent, without their knowledge." Sen. Skip Daly said, "I don't think there should be a reliance on this, and this is where it starts."

A UNLV computer scientist warned of possible model bias and hallucinations. A public-employee union argued AI should not replace worker judgment. Sen. Neal said she plans to reintroduce AI-oversight legislation after an earlier bill failed.

This deference risk is projected by experts, not measured. No referee override or rejection rate has been published.

What this network is drawn from

This network follows the pattern the case file describes. It does not reconstruct the actual AI. It shows the drafting AI, its search of Nevada law and past appeals, the appeals records, the referees, DETR's governance committee, and Google's cloud. Claimants are outside the network.

What the available tools can and cannot address

A failure pathway is a link between two parts of the network where a mistake made by one part can be passed on to the other. A tool closes a pathway when mistakes stop passing along it. The work along it may go on.

This case has a budget of 12 units. Explore (No Targets) sets no targets. The other three levels all ask for the network's mistakes to be contained, meaning corrected rather than building on each other.

Under Service Targets Only, the targets can be met with every tool at its standard setting. The cheapest combinations cost 4 units, and each includes Escalate checks. One is Escalate checks with Gate vendor updates. Escalate checks at its stronger setting also meets them alone, for 4 units.

Under Service and Safety Targets, the targets can be met. This level also asks you to close every failure pathway, among other targets. Six are open before any tool is used. The first three are Drafted ruling handed to the referee, Law and past decisions searched for each draft, and Draft saved to the appeals records. The other three are Signed decision filed in the appeals records, One AI drafts every appeal, and Appeal files processed on Google's cloud.

The cheapest combination costs 10 units: Escalate checks, Gate vendor updates, Gate record entries, and Vet connections. Every combination that meets these targets includes all four. Escalate checks is the only tool on offer that closes the pathway from drafts to the referee.

Under All Governance Targets, one combination within the budget meets the targets, and it spends the whole budget of 12 units. It is the same four tools plus Understand the system. At this level Understand the system costs 4 units. While it is on, four tools cost 1 unit less: Keep skills sharp, Escalate checks, Upgrade model, and Vet connections.

At this level, Vet connections and Check copied records work at full strength only while Understand the system is on. Without it, the four tools leave two pathways open: Law and past decisions searched for each draft, and One AI drafts every appeal.

More is not better here. Using every tool at its strongest setting costs 38 units, over three times the budget. It contains the mistakes and closes every failure pathway. It still meets the targets at none of the three levels that set them, because the drafting AI then adds too little to the work.

Stylized model of a documented deploymentPublic benefits & eligibility

Open this example in PAN Lab v0.1 to apply pressures and levers and watch what the system does.

What this models

This example runs on the Generative-adjudication class: an AI that drafts the ruling for a referee to sign network: 6 components and 12 pathways between them. Every context in the Lab is a stylized model, never a reconstruction of any actual deployment, and each assumption behind it carries a provenance label.

Evidence base: 3 assumed · 5 published baseline. In the Lab, the shaded evidence band behind each headline readout draws its width from the least-established class below.

Show all 8 assumptions
  • assumed

    This network follows the pattern the Nevada DETR case file describes. It does not reconstruct the actual AI, its underlying model, or Google's platform. It is not a risk-scoring, fraud-flagging, or eligibility-screening model, and not a helper that answers caseworkers' benefits questions. The AI drafts the recommended determination and the written decision itself. That makes this a case of AI drafting the ruling on a legal right to benefits, rather than a score handed to someone who decides.

  • baseline

    The safety of this design rests on one referee's sign-off. The AI's stated purpose is to clear a backlog of appeals from the pandemic. So the pathway where the AI hands drafts to the referee is at the center of this network. The AI is meant to cut a determination from as much as several hours to about five minutes. Critics warn that backlog and speed pressure could hollow out the review. The case file argues that under that pressure, a referee who keeps rejecting drafts is cast as the bottleneck.

  • baseline

    The network includes the two-worker sign-off from the start, as a real second look. DETR described two state workers involved and a required referee sign-off. So the human is kept, unlike Michigan's MiDAS system, which decided many cases with no human review. But the review runs under pressure to move fast. No referee override or rejection rate is published, so no one outside knows how deep the review goes. Assign a challenger is the tool that makes the sign-off a scheduled duty.

  • baseline

    The 90 percent requirement is graded by state workers on test decisions, not by an independent outside audit. The sources describe no independent check of each draft, so the network includes one only as something one of the Lab's tools can add. Critics cite outside studies of legal-research software built by the same method. Those found 17 to 33 percent of answers incorrect and 18 to 63 percent incomplete. The studies did not measure Nevada's AI. Officials reported the wrong-statute and incomplete-document problems found in testing as fixed.

  • baseline

    The AI searches a database of prior appeals decisions, so new drafts are written partly from past rulings. The network treats this as a loop that can carry old patterns forward, including any historic bias. The sources describe no check of a drafted ruling against Nevada law before it joins that database. No independent audit of this loop is published.

  • baseline

    The AI runs on Google's cloud platform, where hearing transcripts and evidence are processed. These may contain Social Security numbers and tax, financial, and health details. DETR describes safeguards: data kept in the continental United States, and encryption keys held by the state. Claimants are not required to consent, and no opt-out is described. The network marks this pathway as exposing private data, so Gate vendor updates has a clear target in the contract. The consent and single-vendor concerns are institutional, and the Privacy gauge does not measure them.

  • assumed

    As of the latest reporting, in March 2026, the AI was in delayed testing on past appeals. It was described as launching in the coming weeks. No source confirms it is deciding live claimant appeals. An earlier 2024 projection of launch within months had slipped repeatedly. This network shows the design being built, not a claim that the AI is in use. The repeated delays are themselves a documented fact.

  • assumed

    Claimants are outside the network. The harm this case watches is a wrongly drafted ruling that a referee signs without real review. That harm is recorded outside the network and never computed here. A UNLV computer scientist warned of possible bias and hallucinations. That is a warning, not a measured difference between groups, so the network estimates no harm to any group. The sources read for this case name Google's Vertex AI Studio platform and the retrieval method, but not the specific AI model.

What this example does not show

Show all 3 limitations
  • This example does not show a system confirmed to be deciding live appeals. As of the latest reporting, in March 2026, the AI was in delayed testing on past appeals, described as launching in the coming weeks. An earlier 2024 projection of launch within months had slipped repeatedly. By mid-2026 the coming-weeks window had passed, and no source confirms a launch. Read it as close to launch but not confirmed live. The repeated delays are themselves the documented fact.
  • This example does not show a measured rate of rubber-stamping. The deference risk is projected by legal scholars, attorneys who represent claimants, a former U.S. Department of Labor official, and a legal analysis. An opinion column in The Nevada Independent argues it too. No referee override or rejection rate is published. The 90 percent figure is an acceptance requirement graded by state workers on test decisions, not an independent audit. Some analysts cite error ranges for legal-research software built by the same method: 17 to 33 percent incorrect and 18 to 63 percent incomplete. Those come from general studies, not this system. Officials reported the wrong-statute and incomplete-document problems from testing as fixed.
  • This example does not show claimants or the benefits they do or do not receive. It shows how mistakes pass between the parts of the appeals system. The harm it watches is a wrongly drafted ruling adopted through a sign-off without real review. The case file documents that concern, and it is recorded outside any network like this one. A UNLV computer scientist's warning of bias and hallucinations is a warning, not a measured difference between groups. So no difference in harm between groups is estimated. The sources read for this case name Google's Vertex AI Studio platform and the retrieval method, not the specific AI model.

Sources and evidence

What this example rests on, claim by claim. Every entry resolves to the same ledger the Evidence Registry publishes.

  • Nevada's generative-AI unemployment-appeals tool was justified as a speed measure for a pandemic-era backlog, projecting a drop in referee determination time from as much as several hours to about five minutes per case, with a mandatory human review DETR said adds an estimated 10 to 30 minutes and a required referee sign-off (Director Christopher Sewell said no AI-drafted written decisions issue without human review). Legal scholars, attorneys who represent claimants, and a former U.S. Department of Labor official warned that backlog and speed pressure could hollow out that review and create incentives to rubber-stamp AI outputs -- one attorney noting the time savings only happens if the review is very cursory, and a legal analysis warning staff might feel pressured to authorize AI decisions with haste. That automation-deference risk is expert-projected, not a measured outcome: no referee override or rejection rate has been published, and claimants are not required to consent to AI processing of their appeal.

    empirical
    • Investigative The Markup (Todd Feathers, via Gizmodo), Google's AI Will Help Decide Whether Unemployed Workers Get Benefits (2024) https://gizmodo.com/googles-ai-will-help-decide-whether-unemployed-workers-get-benefits-2000496215
    • Academic Fordham Intellectual Property, Media and Entertainment Law Journal (Dawn Edelman), Speed, Accuracy, and Risk: Nevada's Use of Artificial Intelligence in Unemployment Claims Appeals (2024) http://www.fordhamiplj.org/2024/10/07/speed-accuracy-and-risk-nevadas-use-of-artificial-intelligence-in-unemployment-claims-appeals/
    • Investigative The Nevada Independent (2025, July 22), Nevada will use AI for unemployment appeals; some lawmakers are skeptical (DETR / Google) https://thenevadaindependent.com/article/nevada-will-use-ai-for-unemployment-appeals-some-lawmakers-are-skeptical
  • Nevada's Department of Employment, Training and Rehabilitation contracted Google to build a generative-AI tool on the Vertex AI Studio cloud platform that reads an unemployment-appeal hearing transcript and evidence, retrieves against a corpus of Nevada unemployment law and prior appeals decisions, and drafts a recommended determination (approve, deny, or modify a claim) together with the written decision for a human referee to review and sign. The contract set a 90 percent success requirement self-assessed by state workers on test decisions -- not an independent external audit -- and DETR said it wanted accuracy higher than 90 percent before going live; rollout was repeatedly delayed over less-than-desired accuracy, including the tool citing incorrect Nevada statutes and failing to pull information from all hearing documents, problems officials said were fixed. Reported cost evolved from about 1 million dollars in 2024 to a total of 2.6 million dollars with about 1.1 million spent by early 2026. As of the most recent available reporting (March 2026) the system was in delayed pre-deployment testing on historical appeals and described as launching in coming weeks; it was not independently confirmed to be adjudicating live claimant appeals.

    empirical
    • Investigative The Nevada Independent (2025, July 22), Nevada will use AI for unemployment appeals; some lawmakers are skeptical (DETR / Google) https://thenevadaindependent.com/article/nevada-will-use-ai-for-unemployment-appeals-some-lawmakers-are-skeptical
    • Investigative The Markup (Todd Feathers, via Gizmodo), Google's AI Will Help Decide Whether Unemployed Workers Get Benefits (2024) https://gizmodo.com/googles-ai-will-help-decide-whether-unemployed-workers-get-benefits-2000496215
    • Investigative The Nevada Independent (Eric Neugeboren), Nevada agencies eye artificial intelligence to speed jobless claims, DMV queries (2024) https://thenevadaindependent.com/article/nevada-agencies-eye-artificial-intelligence-to-speed-jobless-claims-dmv-queries
    • Academic Fordham Intellectual Property, Media and Entertainment Law Journal (Dawn Edelman), Speed, Accuracy, and Risk: Nevada's Use of Artificial Intelligence in Unemployment Claims Appeals (2024) http://www.fordhamiplj.org/2024/10/07/speed-accuracy-and-risk-nevadas-use-of-artificial-intelligence-in-unemployment-claims-appeals/

Where this connects

Institutional pressures in this domain

  • Austerity & recovery incentives — Cost-cutting and overpayment-recovery targets tilt the system toward denial and enforcement errors.
  • Vendor opacity — The deploying institution cannot inspect the model, data, or update pipeline it is accountable for.
  • Compliance over substance — Paper controls (sign-offs, checklists) satisfy audits while the behavior they describe erodes.
  • Reviewer bottleneck — One fixed-capacity checking stage sits between AI output and consequence; everything queues behind it.

All of them in context on the Public benefits & eligibility domain page.

Levers available here and the patterns behind them

Documented case histories