A former solicitor has lost an appeal after a Google search produced fabricated case citations that ended up before a court, The Law Society Gazette has reported.

The appellant, who has left the roll, challenged the outcome of disciplinary proceedings brought against him. The dispute centred on citations his legal research turned up through a Google search. The search results included cases that did not exist. Those fake authorities made their way into material put before a court, and the regulator treated the episode as misconduct serious enough to end the solicitor's career at the bar of professional fitness.

The appeal court refused to disturb that outcome.

The case joins a growing line of professional-conduct matters in which generated or retrieved legal material — whether from search engines or artificial intelligence tools — proves to be invented. Courts in several jurisdictions have now penalised practitioners who filed citations they never verified against a primary source. The common thread is simple: the duty to check authority rests with the lawyer, not the tool.

For practitioners, the practical lesson is narrow and unforgiving. Any case cited in a filing, opinion, or skeleton argument must be confirmed against an authorised law report or a recognised subscription database before service. A search-engine result page, an AI chatbot's answer, or a secondary summary is not verification. Where a firm delegates research to junior staff or relies on automated drafting, supervision obligations apply with full force, and the responsible solicitor bears the consequence of any fabricated citation that reaches the court.

The Gazette's report does not indicate whether the solicitor drew any distinction between material generated by a search engine and material generated by artificial intelligence. That distinction may matter in future cases, since some tribunals have shown slightly more sympathy for lawyers misled by tools marketed as authoritative. On the reported facts, the search engine itself surfaced the fake cases, and the appeal court declined to treat that as mitigation sufficient to change the result.

The decision underscores a point regulators on both sides of the Atlantic have repeated throughout the past two years: technological error does not dilute professional responsibility. A solicitor who signs pleadings certifies, in effect, that the authorities cited exist and support the propositions for which they are cited. Where that certification proves false, the sanction follows the solicitor, whatever produced the error.

Compliance teams should treat the ruling as a prompt to review research protocols. Firms that have not yet done so should confirm that their practice-management standards require citation checking against primary sources, document that check, and train staff on the specific risk of hallucinated or fabricated authority. Courts have shown little patience for the excuse, and this appeal outcome confirms that tribunals reviewing sanctions will apply the same standard.

The former solicitor's name no longer appears on the roll. His appeal is dismissed.