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AI in Court

"Incredulity" That "Competent Law Firm Representing One of the Largest Financial Institution[s] in the World" Filed Brief with AI Hallucinations

D.C.’s highest court strikes Deutsche Bank’s appellate brief as a sanction.

Eugene Volokh | 9.4.2026 12:02 PM

From Douglas v. Deutsche Bank Nat'l Trust Co., decided yesterday by D.C. Court of Appeals Judges Catharine Easterly, Vijay Shanker, and Stephen Glickman:

What began as a routine appeal has become a cautionary tale about the misuse of artificial intelligence (AI) and its consequences for attorneys, their clients, and the courts…. While reviewing appellee's [i.e., the Bank'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 Hall has informed the court that she no longer works at the firm and thus no longer represents appellee, although appellee has not moved for her withdrawal from the case.}

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. She recognized that she had a duty to verify the accuracy of every authority submitted to this court and apologized for her failure to do so. As part of this mea culpa, Ms. Hall assured the court that she had taken the remedial measure of verifying that the remaining citations in the brief were legitimate authority and pledged that, going forward (presumably in her representation of other clients), she would not rely on any AI tool "for legal research without confirming each authority" or file anything that includes citations she has not independently verified. Ms. Hall represented that she "deeply regrets this error and the burden it has placed on the [c]ourt and all........

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