Matter of: Adapt Forward, LLC

What the court wrote

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

None of the original citations correctly identified both the case B-number and date; one citation contained an inaccurate B-number. Although the protester provided accurate revised citations, none of the three decisions cited support the asserted proposition. An attorney’s citation of non-existent or inapposite decisions that might have been generated by artificial intelligence may implicate applicable rules of professional conduct. See, e.g., United States v. Hayes, 763 F. Supp. 3d 1054, 2025 U.S. Dist. LEXIS 9408, at *19 (E.D. Cal. 2025) (“Submitting fictitious cases and quotations to the court ‘degrades or impugns the integrity of the Court’ and ‘interferes with the administration of justice’ in violation of Local Rule 180(e), and violates California Rules of Professional Conduct 3.1(a)(2), 3.3(a)(1), and 3.3(a)(2).”). We therefore advise attorneys appearing before our Office that the citation of non-existent authority may result in referral to appropriate bar associations or other disciplinary bodies. 10 That regulation states: A procuring activity has discretion whether to require a protégé or lead small business member of a joint venture to demonstrate some level of past performance and/or experience. It may rely solely on the past performance (continued...)

Authorities cited in the passage: SRA Int’l, Inc · Boeing Sikorsky Aircraft Support · Caci, Inc · United States v. Hayes