Sanction teardown · GAO, USA · 2026-06-16
OS-DB-JV-2, LLC
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)One of four cited GAO decisions could not be located; protester later admitted the citation was erroneous and introduced via research software/AI.
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Fabricated (Case Law)Second cited GAO decision could not be verified; GAO requested copies and protester acknowledged error from software tools.
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Fabricated (Case Law)Third cited GAO decision was unlocatable; GAO found hallmarks of LLM/AI generation and protester apologized for the erroneous citation.
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Fabricated (Case Law)Fourth cited GAO decision could not be found; protester attributed the inclusion to software-assisted research and accepted responsibility.
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/2459/OS-DB-JV-2_LLC_B-242382_6.16.2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).