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Douglas v. Deutsche Bank National Trust Company

Court
D.C. Court of Appeals
Jurisdiction
USA
Decided
2026-09-03
AI tool
Google AI
Outcome
Brief Stricken; Bar Referral
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | The appellee's brief cited a nonexistent case purportedly named Abadie v. District of Columbia; the attorney admitted the authority was not legitimate, and the court declined to reproduce the fabricated citation. || Fabricated: Case Law | The appellee's brief cited a nonexistent case purportedly named Cason v. National Consumer Co-op Bank; the attorney admitted the authority was not legitimate, and the court declined to reproduce the fabricated citation. || Fabricated: Case Law | The appellee's brief cited a nonexistent case purportedly named Osborne v. District of Columbia; the attorney admitted the authority was not legitimate, and the court declined to reproduce the fabricated citation. || Fabricated: Case Law | The appellee's brief cited a nonexistent case purportedly named Woods v. United States; the attorney admitted the authority was not legitimate, and the court declined to reproduce the fabricated citation.

Sanction teardown · D.C. Court of Appeals, USA · 2026-09-03

Douglas v. Deutsche Bank National Trust Company

What happened

In D.C. Court of Appeals, USA, a filing relied on Google AI to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    The appellee's brief cited a nonexistent case purportedly named Abadie v. District of Columbia; the attorney admitted the authority was not legitimate, and the court declined to reproduce the fabricated citation.
  • Fabricated (Case Law)
    The appellee's brief cited a nonexistent case purportedly named Cason v. National Consumer Co-op Bank; the attorney admitted the authority was not legitimate, and the court declined to reproduce the fabricated citation.
  • Fabricated (Case Law)
    The appellee's brief cited a nonexistent case purportedly named Osborne v. District of Columbia; the attorney admitted the authority was not legitimate, and the court declined to reproduce the fabricated citation.
  • Fabricated (Case Law)
    The appellee's brief cited a nonexistent case purportedly named Woods v. United States; the attorney admitted the authority was not legitimate, and the court declined to reproduce the fabricated citation.

Which AI tool

Google AI. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Brief Stricken; Bar Referral

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://reason.com/volokh/2026/09/04/incredulity-that-competent-law-firm-representing-one-of-the-largest-financial-institutions-in-the-world-filed-brief-with-ai-hallucinations/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://reason.com/volokh/2026/09/04/incredulity-that-competent-law-firm-representing-one-of-the-largest-financial-institutions-in-the-world-filed-brief-with-ai-hallucinations/

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