Court Strikes Deutsche Bank Brief After AI-Generated Fake Citations Discovered

In the appeal of Douglas v. Deutsche Bank Nat'l Trust Co., the D.C. Court of Appeals identified several citations in the bank's brief that did not correspond to any real cases. Loishirl W. Hall, who filed the brief, admitted she relied on Google's generative AI to locate authorities and failed to verify them, later acknowledging that four citations were fictitious. The firm that employed Hall claimed ignorance of her methods and cited internal policies prohibiting AI use without verification, though it provided no evidence of oversight.

Judges Easterly, Shanker and Glickman struck the brief, rejected the firm's suggestion to merely redact the false citations, and sent the case to the Office of Disciplinary Counsel for possible investigation. The opinion emphasized that attorneys must personally read and confirm every authority, warning that AI hallucinations pose a broader risk to legal practice.