Courts on AI / Fabricated or misquoted citations
Douglas v. Deutsche Bank National Trust Company
District of Columbia Court of Appeals · State supreme courts · DC · · No. 24-CV-1099 · order
The District of Columbia Court of Appeals strikes Deutsche Bank’s appellee brief after counsel admits that four cited authorities generated through Google’s AI search did not exist. The court also refers the matter to disciplinary counsel and stresses that signed appellate briefs require verified authorities.
- Disposition
- The court struck Deutsche Bank's appellee brief and referred the matter to the Office of Disciplinary Counsel.
- Recorded conduct
- Counsel cited four nonexistent cases in an appellee brief after using Google’s generative AI search tool without verifying the authorities. — outcome: referral; actor: lawyer
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
While reviewing appellee’s brief, the court discovered that it contained multiple citations to cases that the court was unable to locate or confirm as legitimate. On June 22, we issued an order requiring appellee to show cause “why the court should not strike its brief for citing nonexistent cases that are possibly the product of artificial intelligence (AI) hallucinations.” The next day, one of appellee’s attorneys at the firm, Loishirl W. Hall, filed a response in her own capacity. Ms. Hall confirmed that four of the brief’s cited authorities did not exist. She acknowledged that these citations were “not legitimate legal authority” and “should not have appeared in a brief filed with this Court.” Ms. Hall explained that she had “used Google’s generative artificial intelligence search tool to assist in locating case authority” and did not verify the existence or accuracy of those citations before filing the brief.
Authorities cited in the passage: Abadie v. District of Columbia · Cason v. Nat’l Consumer Co-op Bank · Osborne v. District of Columbia · Woods v. United States
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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