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D.C. Court of Appeals strikes Deutsche Bank brief over Google AI citations
The D.C. Court of Appeals struck a Deutsche Bank appellee brief after counsel used Google's generative AI search tool without verifying four nonexistent cases.
Edited and verified by Cognesio LLP
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In the District of Columbia, the Court of Appeals struck a Deutsche Bank appellee brief after counsel admitted she had used Google’s generative AI search tool to locate case authority and had not verified the citations before filing.
The 3 September 2026 published order in Douglas v. Deutsche Bank National Trust Co., No. 24-CV-1099, identified four cited authorities that did not exist. Attorney Loishirl W. Hall was one of the attorneys listed on Deutsche Bank’s brief. When the court asked for an explanation, Hall said she had used Google’s generative AI search tool and did not independently verify the citations.
In the District of Columbia Court of Appeals, Deutsche Bank’s appellee brief cited four nonexistent authorities after counsel used Google’s generative AI search tool without verification. The court struck the brief, referred the matter to the Office of Disciplinary Counsel and sent the sanctions-authority question to its Rules Committee.
What the court did
The court struck Deutsche Bank’s appellee brief rather than deciding the appeal on a filing supported by nonexistent authority. It also referred the matter to the District of Columbia Office of Disciplinary Counsel for whatever investigation that office considers appropriate.
The order separately referred the sanctions issue to the court’s Rules Committee for analysis and possible clarification of the court’s authority over hallucinated-citation filings in appellate practice.
Why it matters
The order is important for two reasons. First, it names the tool category: Google’s generative AI search was used to find case authority. Second, the court treated the error as an appellate-practice problem, not just an embarrassment in the record. Striking the brief changes the posture of the appeal; a disciplinary referral creates a separate professional-conduct track.
For lawyers, the operational rule is familiar but unforgiving: a citation found with AI is not authority until it has been opened and checked against the actual source.
Record: Douglas v. Deutsche Bank National Trust Co..