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Courts on AI / Fabricated or misquoted citations

Endure Industries, Inc. v. Defense Health Agency

Armed Services Board of Contract Appeals · Federal specialty courts · · No. ASBCA No. 64064 · opinion

Fabricated or misquoted citations

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 granted dismissal and warned the self-represented contractor that future citations to non-existent authority may lead to sanctions.
Recorded conduct
The brief used fabricated or nonexistent authorities and mischaracterized authorities, including LLC v. United States and Corp. v. United States, which the court found nonexistent, misquoted, or unsupported. — outcome: warning; 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

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