OOF-AII-291063

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

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.

Event date
2025-08-12
Country
United States of America
Severity
Low
Evidence state
Single-source

Assessment status

Generated from available public incident evidence using OOF® governance methodology. It is not an official investigation, legal determination, regulatory finding, certification, or OOF® Approved Assessment.

View source record from AI Incident Database (Responsible AI Collaborative)

Assessment confidence dimensions

Source corroboration
Single-source

Measures source-group corroboration only; it does not establish factual truth.

Extraction completeness
Moderate

Measures populated source fields after deterministic normalization; it does not measure correctness.

Methodological assignment confidence
Moderate

Measures automated assignment support; substantive correctness requires authorized human review.

Known facts from the incident record

  • The incident record identifies the event date as 2025-08-12.
  • The incident record identifies the location as United States of America.

Reported claims

  • 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.

Material unknowns

  • Independent corroboration is not established in the available incident record.

Primary governance problem

The incident appears to expose a governance problem involving trust, tool, authority. Available reporting supports preliminary methodological interpretation, not a finding of fault or non-compliance.

Architecture intelligence

ASGA™ — Autonomous Systems Governance Architecture

Primary architecture

The reported trust, tool, authority concern falls within the governed questions represented by ASGA™ — Autonomous Systems Governance Architecture.

Governance focus: How should trust, tool, authority be governed in the conditions described by the available incident evidence?

Deeper methodology is withheld because the available evidence does not justify a Parent Standard or Core Module.

Preliminary governance questions

  • How should trust, tool, authority be governed in the conditions described by the available incident evidence?
  • What operational authority and controls applied to Loishirl W. Hall, Lawyers, Legal Professionals at the relevant time?
  • What evidence would establish how Google Search, Ai Assisted Legal Research Systems produced or enabled the reported outcome?
  • What additional independent evidence is required to resolve the material evidence gaps?

Evidence gaps and limitations

  • Only one independent source group is represented; corroboration is not established.
  • AI technology is not specified in the source record.
  • industry is not specified in the source record.
  • AI system type is not specified in the source record.

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