Courts on AI / Fabricated or misquoted citations

Appeal of Endure Industries, Inc.

Armed Services Board of Contract Appeals · Federal specialty courts · 2026-03-23 · No. ASBCA No. 64064 · opinion

On 2026-03-23, Armed Services Board of Contract Appeals the Board granted dismissal and warned the self-represented contractor that future citations to non-existent authority may lead to sanctions. A self-represented party submitted a brief with fabricated or nonexistent authorities and mischaracterized authorities, including LLC v. United States and Corp. v. United States.

Disposition: The Board dismissed part of the appeal with prejudice, part without prejudice, and ignored the fake and inaccurate legal citations rather than striking the whole brief.
Recorded conduct: Endure acknowledged using a generative AI program and cited one nonexistent decision, BMS, Inc. v. United States, plus other decisions that did not support the cited propositions. — outcome: filing struck; actor: litigant in person
Canonical record: Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

– have a tendency to hallucinate non-existent cases. Sanders v. United States, 176 Fed. Cl. 163, 169 (2025) (“It is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs.”); Raven Investigations & Sec. Consulting, LLC, B-423447, 2025 CPD ¶ 81 at 3 (“[T]he use of AI programs to draft or assist in drafting legal briefs can—and seemingly often does—result in the citation of non-existent cases.”); see also Ralph Nash, Artificial Intelligence Hallucinations: Sanctions are Waiting, 39 NASH & CIBINIC REP. ¶ 44 (Aug. 2025) (“[I]t is well known that so far AI programs tend to hallucinate.”). The real decision near the hallucinated citation is Johns-Manville Corp. v. United States, 12 Cl. Ct. 1 (1987). “Fake cases generated by AI often have reporter citations that lead to cases with different names, in different courts, and about different subjects.” Sanders, 176 Fed. Cl. at 169 n.8. Endure asserts that the Johns-Manville decision supports the assertions made in its brief

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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