Courts on AI / Fabricated or misquoted citations

G2 Ops, Inc.

Government Accountability Office · Federal specialty courts · 2026-02-13 · No. B-423967 · opinion

Government Accountability Office on 2026-02-13 in G2 Ops, Inc. found counsel's response to dismissal cited nonexistent case law that GAO said bore hallmarks of AI or large-language-model use without verification. GAO denied the protest in part, dismissed it in part, and warned that future submissions with nonexistent authority may lead to sanctions.

Disposition: GAO denied the protest in part, dismissed it in part, and warned that future submissions with nonexistent authority may lead to sanctions.
Recorded conduct: Counsel's response to dismissal cited nonexistent case law that GAO said bore hallmarks of AI or large-language-model use without verification. — outcome: warning; actor: lawyer
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.

The agency requested dismissal of the protest and in its response, the protester cited to certain cases in support of its argument against dismissal. After the intervenor requested clarification on these cited cases, the protester’s counsel acknowledged that the response included citations to non-existent caselaw. Electronic Protest Docketing System (EPDS) Docket Entries No. 21 Request for Clarification on Cases Cited by Protester; No. 22, Request to Substitute Response to Dismissal Request and Acknowledgment of Citation Error. G2 Ops’ erroneous citations bear the hallmarks of the use of a large-language model or other artificial intelligence (AI) without adequate verification that the generated results were accurate. See KE Sys. Servs., Inc., B-423881 et al., Dec. 22, 2025, at 6. The use of AI programs to draft or assist in drafting legal filings can result in the citation of non-existent decisions, such that reliance on those programs without review for accuracy wastes the time of all parties and GAO. KE Sys. Servs., Inc., supra; Raven Investigations & Sec. Consulting, LLC, B-423447, May 7, 2025, at 4. As we have explained, our Office necessarily reserves an inherent right to dismiss any protest and to impose sanctions against a protester, where a protester’s actions undermine the integrity and effectiveness of our process. Raven Investigations & Sec. Consulting, LLC, supra. The protester’s counsel is advised that any future submission of filings to our Office with citations to non-existent authority may, after reviewing the totality of the circumstances, result in the imposition of sanctions. Id. Page 8 B-423967

Authorities cited in the passage: and GAO

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: official copy pending

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