What was hallucinated

Fabricated: Case Law | Cited a non-existent ASBCA decision and incorrect reporter pin (case not found and reporter entry refers to a different appeal). Board could not find ASBCA No. 29708 as cited. || Fabricated: Case Law | Cited a case name that does not correspond to the reporter entry and appears not to exist in ASBCA decisions identified by the Board. || Misrepresented: Case Law | Cited Grumman Aerospace with an incorrect reporter citation and relied on the citation for a proposition not supported by the actual decisions the Board located. || Misrepresented: Case Law | Relied on a reporter entry and ASBCA reference that did not support the asserted rule; Board found the cited reporter entry involved different parties/subjects. || Misrepresented: Case Law | Cited a reporter entry and case (Env’t Safety Consultants) that either was the wrong reporter or did not support the claimed legal proposition. || Misrepresented: Case Law | Cited a federal appellate decision for a proposition about burden shifting though the cited page discusses a different doctrine; the case did not support the claimed rule. || Misrepresented: Exhibits & Submissions | Cited transcript pages as containing expert testimony that the Board found were testimony of a different witness and did not support the asserted facts. || Misrepresented: Exhibits & Submissions | Cited transcript pages as supporting factual assertions, but the cited pages discuss unrelated topics; Board found the transcript did not contain the alleged testimony. || Fabricated: Exhibits & Submissions | Cited non-existent transcript pages (pages contain reporter certificates or are beyond transcript length) to support factual claims. || Fabricated: Exhibits & Submissions | Cited transcript pages that do not exist (volume ends earlier) to attribute concessions to the contracting officer; Board noted the pages cited were beyond the transcript's length.

Details

The Board found over 70% of citations in Huffman's reply brief inaccurate, including fabricated cases, misattributed reporter citations, cases that did not support cited propositions, and incorrect or non-existent transcript/Rule 4 citations. Counsel admitted using AI to generate portions of the brief. The Board treated the motion as one for Rule 11-type sanctions and struck the reply brief; it emphasized attorneys' duty to verify AI-generated content.

Sanction teardown · ASBCA, USA · 2025-10-23

Appeals of Huffman Construction, LLC

What happened

In ASBCA, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Cited a non-existent ASBCA decision and incorrect reporter pin (case not found and reporter entry refers to a different appeal). Board could not find ASBCA No. 29708 as cited.
Fabricated (Case Law)

Cited a case name that does not correspond to the reporter entry and appears not to exist in ASBCA decisions identified by the Board.
Misrepresented (Case Law)

Cited Grumman Aerospace with an incorrect reporter citation and relied on the citation for a proposition not supported by the actual decisions the Board located.
Misrepresented (Case Law)

Relied on a reporter entry and ASBCA reference that did not support the asserted rule; Board found the cited reporter entry involved different parties/subjects.
Misrepresented (Case Law)

Cited a reporter entry and case (Env’t Safety Consultants) that either was the wrong reporter or did not support the claimed legal proposition.
Misrepresented (Case Law)

Cited a federal appellate decision for a proposition about burden shifting though the cited page discusses a different doctrine; the case did not support the claimed rule.
Misrepresented (Exhibits & Submissions)

Cited transcript pages as containing expert testimony that the Board found were testimony of a different witness and did not support the asserted facts.
Misrepresented (Exhibits & Submissions)

Cited transcript pages as supporting factual assertions, but the cited pages discuss unrelated topics; Board found the transcript did not contain the alleged testimony.
Fabricated (Exhibits & Submissions)

Cited non-existent transcript pages (pages contain reporter certificates or are beyond transcript length) to support factual claims.
Fabricated (Exhibits & Submissions)

Cited transcript pages that do not exist (volume ends earlier) to attribute concessions to the contracting officer; Board noted the pages cited were beyond the transcript's length.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Reply brief struck in its entirety

Additional detail

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/1040/Huffman_Construction_LLC_Hamady_10.23.25_Non-Disp_Decision.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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