Sanction teardown · ASBCA, USA · 2026-03-13
DSME Construction Co., Ltd.
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:
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Fabricated (Case Law)December 1, 2025 surreply contained eight citations to cases that do not exist; Board accepted appellant's admission and struck the surreply.
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Fabricated (Case Law)Opening brief included one citation to a non-existent case (admitted by appellant).
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Fabricated (Case Law)January 9, 2026 brief on the vitiation issue cited one fictitious case (admitted by appellant).
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Fabricated (Legal Norm)Briefs included fictitious Federal Acquisition Regulation (FAR) citations (government identified four fictitious FAR cites).
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Misrepresented (Case Law)Government identified several citations that misrepresented the holdings of existing cases (some citations appeared to misstate holdings).
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
Brief struck
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.
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Source: https://www.damiencharlotin.com/documents/1875/dsme_construction_co._ltd._63878.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).