Sanction teardown · GAO, USA · 2026-01-28
Matter of: Bramstedt Surgical Inc.
What happened
In GAO, 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)Protester cited a non-existent decision combination (party name, B-number, and date) that GAO could not locate.
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Fabricated (Case Law)Protester cited a partially accurate citation (party name and B-number exist but date/matter do not match the cited proposition).
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Fabricated (Case Law)Protester cited a B-number/party combination GAO could not locate and that was irrelevant to the asserted timeliness principle.
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Fabricated (Case Law)Protester cited a party name with a B-number/date that did not correspond to the GAO decision addressing the cited issue.
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Fabricated (Case Law)Protester cited a B-number that matched a different decision and a party name/date that did not align with the cited authority.
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Fabricated (Case Law)Protester cited a party name and B-number/date combination that did not match GAO precedent relied on; GAO found multiple mismatches for this party name across different B-numbers/dates.
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Fabricated (Case Law)Appendix included four additional GAO decisions with inaccurate citations that the protester later withdrew reliance on.
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
Warning
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/1425/Bramstedt_Surgical_Inc_USA_28_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).