Courts on AI / Fabricated or misquoted citations
Matter of The JAAW Group, LLC
Government Accountability Office · Federal specialty courts · · No. B-424433.22 · opinion
GAO dismisses JAAW’s bid protest as factually insufficient and separately addresses AI-associated citation problems. The decision notes one nonexistent GAO citation and one irrelevant Federal Circuit citation, declines sanctions because dismissal rests on other grounds, and warns future filings may be sanctioned.
- Disposition
- GAO dismissed the protest on factual insufficiency and warned that future nonexistent or irrelevant citations may lead to sanctions.
- Recorded conduct
- Protester submitted one nonexistent GAO decision citation and one Federal Circuit citation unrelated to the solicitation-ambiguity proposition asserted. — 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.
In addition to the factual inaccuracies discussed above, JAAW offered, in support of its protest arguments, citations to five bid protest decisions--two decisions of our Office and three decisions of the U.S. Court of Appeals for the Federal Circuit. ... Based on these inaccurate legal citations, the Army posited that JAAW’s protest “bears indicia consistent with the use of a large-language model or other artificial intelligence (AI)” tool. ... The Army correctly notes that two citations in JAAW’s July 2, 2026 GAO protest require correction. JAAW acknowledges these errors and takes full responsibility: 1. Tyco Electronics Corp., B-411937: The Army was unable to locate this decision. JAAW has independently verified that this citation as presented does not correspond to a published GAO decision. JAAW withdraws this citation. ... 2. Impresa Construzioni Geom. Domenico Garufi v. United States, 238 F.3d 1324 (Fed. Cir. 2001): The Army correctly notes that this case addresses a contractor responsibility determination, not solicitation ambiguity. JAAW withdraws the citation as applied to the ambiguity argument. ... while there is nothing inherently wrong with the proper and competent use of AI tools in the legal arena, this evolving technology has many glitches--including hallucinations--and must only be used with close, careful supervision, fact-checking, and citation-checking. ... Here, because we dismiss the protest for failing to set forth a factually sufficient basis of protest, we do not exercise our right to impose sanctions for JAAW’s submission of one non-existent citation and one wholly irrelevant citation. The protester, however, is advised that any future submissions of filings to our Office with citations to non-existent or wholly irrelevant authority may, after a review of the totality of the circumstances, result in the imposition of sanctions.
Authorities cited in the passage: Tyco Electronics Corp., B-411937 · Impresa Construzioni Geom. Domenico Garufi v. United States, 238 F.3d 1324 (Fed. Cir. 2001) · KE System Servs., Inc., B-423881 · Raven Investigations & Sec. Consulting, LLC, B-423447 · 4 C.F.R. § 21.1(c)(4)
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
Hugging Face