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DC appeals court blames Deutsche Bank lawyers…
Artificial Intelligence & Robotics
DC appeals court blames Deutsche Bank lawyers for AI hallucinations
September 4, 2026, 1:53 pm CDT

Calling it a “cautionary tale about the misuse of artificial intelligence,” the District of Columbia Court of Appeals struck down a Deutsche Bank subsidiary’s appellate brief in an ongoing mortgage foreclosure lawsuit after finding that it cited nonexistent cases. (Image from Shutterstock)
Calling it a “cautionary tale about the misuse of artificial intelligence,” the District of Columbia Court of Appeals struck down a Deutsche Bank subsidiary’s appellate brief in an ongoing mortgage foreclosure lawsuit after finding that it cited nonexistent cases.
Reuters reported Thursday that a unanimous three-judge panel had found multiple instances of fake cases cited in the subsidiary’s brief.
According to the opinion, the subsidiary’s lawyer, Loishirl Hall, formerly of the law firm McCabe, Weisberg & Conway, admitted that four of the citations had been hallucinated by Google’s generative AI tool and “should not have appeared in a brief filed with this court.”
The D.C. appeals court, however, found that while Hall had taken responsibility for the hallucinations, her co-counsels were also at fault.
“Every firm attorney who signed the brief bears some responsibility,” the three-judge panel wrote in a per curiam opinion.
The appeals court maintained that it was not out to stop or discourage lawyers from using AI.
“We have reached a point where attorneys eschew at least an understanding, if not use, of AI at their own peril,” the opinion said.
Nevertheless, the D.C. appeals court emphasized the importance of using AI correctly and responsibly.
“A brief containing fake citations masquerades as useful advocacy, but it misdirects the court, burns time and resources, and sows confusion while the court gets to the bottom of the matter. By then, the damage is done: The court is left without real guidance from one side of the adversarial equation, and the client is left without a credible advocate,” the opinion stated.
The panel ultimately struck the subsidiary’s brief in its entirety and referred the matter to the District of Columbia Bar’s Office of Disciplinary Counsel.
In a separate opinion, District of Columbia Court of Appeals Senior Judge Stephen Glickman said while he concurred with the result, he thought that the per curiam opinion did not sufficiently examine the issue of AI use, attorneys’ responsibilities and potential sanctions.
Reuters stated that it reached out to Hall and her former firm for comment and did not hear back.
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