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Courts on AI / Fabricated or misquoted citations

Mission Critical Project Services, Inc.

U.S. Government Accountability Office · Federal specialty courts · · No. B-424081.2 · opinion

Fabricated or misquoted citations

On 2026-03-26, U.S. Government Accountability Office warned the protester that future filings with non-existent authority may result in sanctions after reviewing erroneous AI-like citations. Counsel submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities. The warning applied to later filings in the same case.

Disposition
The Office warned the protester that future filings with non-existent authority may result in sanctions after reviewing erroneous AI-like citations.
Recorded conduct
The filing used fabricated or nonexistent authorities and mischaracterized authorities that the court found nonexistent, misquoted, or unsupported for the propositions asserted. — 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.

propositions asserted by MCPS, and non-existent decisions. See Electronic Protest Docketing System (Dkt.) No. 8, Response to Dismissal Request; Dkt. No. 12, Appendix A, GAO Decisions Cited. MCPS’ 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. 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, supra. The protester is advised that any future submission of filings with citations to non-existent authority may, after a review of the totality of the circumstances, result in the imposition of sanctions. Id. Page 6 B-424081.2

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