Attorney AI use
Deutsche Bank National Trust Co. v. LeTennier
At least 23 fabricated cases appeared across five filings, continued after warning, and were followed by a reluctant AI admission.
$10,000 in sanctions01
Case background
Material facts
Counsel repeatedly filed papers containing invented authorities. The conduct continued after opposing counsel flagged the problem, and the role of generative AI was not candidly acknowledged at first.
02
The decision
The court’s ruling
The lawyer was sanctioned $5,000 for unverified generative-AI use and another $2,500 for a frivolous appeal; the client was sanctioned $2,500.
Why it matters
What the decision means
Repeated use after notice converts a preventable verification failure into sustained litigation misconduct. A warning should trigger an immediate audit of every affected filing.
Primary reading