Was Douglas v. Deutsche Bank National Trust Co. sanctioned over AI-generated citations?

Douglas v. Deutsche Bank National Trust Co. (D.C. Court of Appeals, September 3, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Appellee's brief stricken under D.C. App. R. 28; matter referred to the Office of Disciplinary Counsel; sanctions-authority question referred to the court's Rules Committee. No monetary penalty in this order.

Which AI tool was involved in Douglas v. Deutsche Bank National Trust Co.?

The matter records Google AI search tool as the generative tool associated with the unverified citations in Douglas v. Deutsche Bank National Trust Co..

September 3, 2026 · AI sanctions database

Douglas v. Deutsche Bank National Trust Co.

Douglas v. Deutsche Bank National Trust Co. is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: D.C. Court of Appeals
Date: September 3, 2026
Party: Lawyer
AI tool: Google AI search tool
Outcome: Appellee's brief stricken under D.C. App. R. 28; matter referred to the Office of Disciplinary Counsel; sanctions-authority question referred to the court's Rules Committee
Penalty: No monetary penalty in this order.

Bar referralProfessional sanction

What the record shows

The District of Columbia Court of Appeals struck a mortgage trustee's appellate brief in a judicial foreclosure appeal after the court could not locate several cited cases. Responding to a show-cause order, one of the attorneys confirmed four cited authorities did not exist and stated she had used Google's generative AI search tool to locate case authority without verifying it. The firm said it was unaware of her use and that its policy bars AI drafting. The court held every attorney listed on the brief bears some responsibility, struck the brief, and referred the matter to the Office of Disciplinary Counsel. A concurrence noted this was the court's first reported brief with such citations.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗ · CourtListener record ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · D.C. Court of Appeals

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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