HISPI Project Cerebellum HISPI PROJECT CEREBELLUM

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

August 12, 2025

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.

The incident serves as a reminder that AI models must be used responsibly to avoid harm in our justice system. The HISPI Project Cerebellum TAIM will continue to monitor and address these types of incidents to ensure safe and secure AI development.

To prevent similar incidents, we encourage all attorneys and researchers to use established best practices for citation management and to seek guidance from experienced professionals when unsure about the accuracy of their work. By working together, we can build a more trustworthy AI ecosystem.

Matched TAIM controls

Suggested mapping from embedding similarity (not a formal assessment). Browse all TAIM controls

Alleged deployer
loishirl-w.-hall, lawyers, legal-professionals
Alleged developer
google
Alleged harmed parties
district-of-columbia-court-of-appeals, courts, legal-clients, judicial-integrity, epistemic-integrity, parties-to-legal-proceedings

AI governance case studies

For forensic AI governance failure analysis (TAIMScore™ case studies), browse Human Signal’s Failure Files™.

Source

Data from the AI Incident Database (AIID). Cite this incident: https://incidentdatabase.ai/cite/1682

Data source

Incident data is from the AI Incident Database (AIID).

When citing the database as a whole, please use:

McGregor, S. (2021) Preventing Repeated Real World AI Failures by Cataloging Incidents: The AI Incident Database. In Proceedings of the Thirty-Third Annual Conference on Innovative Applications of Artificial Intelligence (IAAI-21). Virtual Conference.

Pre-print on arXiv · Database snapshots & citation guide

We use weekly snapshots of the AIID for stable reference. For the official suggested citation of a specific incident, use the “Cite this incident” link on each incident page.