Incident Tracker / United States (state)
Douglas v. Deutsche Bank National Trust Co., No. 24-CV-1099 (D.C. Ct. App.)
·District of Columbia Court of Appeals·US-STATERegulatory referral
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.
- Court
- District of Columbia Court of Appeals
- Date
- 2026-09-03
- Who used the AI
- Lawyer
- AI tool
- Google generative AI search tool
- Conduct
- Appellee Deutsche Bank's brief cited four authorities that did not exist. Attorney Loishirl W. Hall told the court she used Google's generative AI search tool to locate case authority and did not verify the citations; the court struck the brief, referred the matter to disciplinary counsel, and asked its Rules Committee to review sanction authority.
- Outcome
- Regulatory referral
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- District of Columbia Office of Disciplinary Counsel: The Court of Appeals struck appellee's brief and referred the matter to the Office of Disciplinary Counsel for any investigation it deems appropriate. No disciplinary disposition is yet on record. (2026-09-03)
- Status
- Verified against listed sources
- Last checked
- 2026-09-04
What was fabricated or misused
- Abadie v. District of Columbia — full fake citation omitted by the court
- Cason v. Nat’l Consumer Co-op Bank — full fake citation omitted by the court
- Osborne v. District of Columbia — full fake citation omitted by the court
- Woods v. United States — full fake citation omitted by the court
What the court said
“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.”
“As such, we deem it appropriate to strike appellee’s brief. We also refer this matter to the Office of Disciplinary Counsel for any investigation it deems appropriate.”
Timeline
- Appeal was submitted for decision without argument.
- Court ordered Deutsche Bank to show cause over possibly hallucinated citations.
- Hall confirmed four cited authorities did not exist.
- Court struck the brief and referred the matter to disciplinary counsel.
Why this case matters
Douglas updates the Mata pattern for appellate practice and search-integrated AI. The tool was not a chatbot named in a prompt; counsel said it was Google's generative AI search tool. The Court of Appeals struck the appellee brief, referred the matter to discipline, and sent the sanctions-authority question to its Rules Committee. The order also put responsibility on every lawyer who signed the brief, not only the lawyer who ran the search, making firm review a live issue.
Practice note
A law firm brief should have a citation-check step tied to the signer, not to the person who found the case. Search-generated authority should be treated as a lead only. Before filing, each cited case must be opened, read for the proposition, and checked for jurisdiction and status; a firm AI policy should require proof of that review.
Primary sources for this incident
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, “Douglas v. Deutsche Bank National Trust Co., No. 24-CV-1099 (D.C. Ct. App.)”, safelegalai.com/tracker/douglas-v-deutsche-bank-national-trust (accessed 2026-10-07). Data: CC BY 4.0.