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Incident 1682: D.C. Court of Appeals Struck Deutsche Bank National Trust Company Brief After Attorney Used Google Generative AI Search Tool and Filed Four Nonexistent Case Citations

Description: In Douglas v. Deutsche Bank National Trust Co., attorney Loishirl W. Hall acknowledged using Google's generative AI search tool to locate case authority and failing to verify citations before an appellate brief was filed. The D.C. Court of Appeals found four cited cases did not exist, said the filing misdirected the court and burdened judicial resources, struck Deutsche Bank's brief, and referred the matter for disciplinary review.

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Alleged: Google developed an AI system deployed by Loishirl W. Hall , Lawyers and Legal professionals, which harmed District of Columbia Court of Appeals , Courts , Legal clients , Judicial integrity , Epistemic integrity and Parties to legal proceedings.
Alleged implicated AI systems: Google Search and AI-assisted legal research systems

Incident Stats

Incident ID
1682
Report Count
2
Incident Date
2025-08-12
Editors
Daniel Atherton

Incident Reports

Reports Timeline

Incident Occurrence+1
DC court faults lawyers for Deutsche Bank subsidiary over AI hallucination
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DC court faults lawyers for Deutsche Bank subsidiary over AI hallucination

DC court faults lawyers for Deutsche Bank subsidiary over AI hallucination

reuters.com

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Douglas v. Deutsche Bank National Trust Co., No. 24-CV-1099, Published Order

Douglas v. Deutsche Bank National Trust Co., No. 24-CV-1099, Published Order

fingfx.thomsonreuters.com

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DC court faults lawyers for Deutsche Bank subsidiary over AI hallucination
reuters.com · 2026

The District of Columbia Court of Appeals said in a ruling on Thursday, opens new tab that lawyers for a Deutsche Bank subsidiary in a mortgage foreclosure lawsuit cited nonexistent cases generated by artificial ​intelligence, calling the m…

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Douglas v. Deutsche Bank National Trust Co., No. 24-CV-1099, Published Order
fingfx.thomsonreuters.com · 2026

AIID Editor’s Note: This Markdown transcription was prepared from the original court PDF for AIID archival and search use. It preserves the full extracted text, but Markdown cannot reproduce the PDF’s authoritative legal formatting. Consul…

Variants

A "variant" is an AI incident similar to a known case—it has the same causes, harms, and AI system. Instead of listing it separately, we group it under the first reported incident. Unlike other incidents, variants do not need to have been reported outside the AIID. Learn more from the research paper.
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