Federal · federal court · 2025

Huffman Construction, LLC

Armed Services Board of Contract Appeals, 23 October 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · A.S.B.C.A.

  1. Court. Armed Services Board of Contract AppealsCOURT
  2. Level. federal courtLEVEL
  3. Date. 23 October 2025DATED
  4. Docket. No. 62591, 62783DOCKET
  5. Judge. HamadyJUDGE
  6. Documents. one document, 8 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 23 October 2025 · source · PDF · 16 pages

The Corps identified each of the alleged false or misleading citations and explained in detail why each was false or misleading. Among these include citations to fictitious case law, hearing testimony from witnesses who never testified at the hearing, documents not found in the Rule 4 file, pages of the hearing transcript that do not exist, testimony found in hearing transcripts that do not support the factual contention for which they were cited, and citations to cases that do not support the proposition for which they were cited. (Id.) 6.

The cited Rule 4 tab is not an Ideal field service report, but a letter from Huffman to the contracting officer and it does not mention an Ideal field service report. Fictitious Cases and Incorrect citations c. Huffman’s counsel cited Santa Fe Engineers, Inc., ASBCA No.

Instead, the testimony discusses whether the site at present was ninety-five (95%) complete. Citations to non-existent pages in the hearing transcripts n. Huffman’s counsel represented that pages 98-99 of volume three of the hearing transcript supported the statement that, “This meant that until the pump and motor scope advanced to the commissioning phase, the main electrical feeders for dependent systems could not be brought online” (app. reply at 16).

Huffman’s counsel represented that pages 144-46 of volume five of the hearing transcript support the statement that the contracting officer “stated that completion was ‘critical’ without addressing the fact that the re-procurement contract was not issued until five years following termination . . . .” (app. reply at 18). The cited pages do not exist because volume five of the hearing transcript ends on page 116. p. Huffman’s counsel represented that pages 118-19 of volume five of the hearing transcript contain the contracting officer’s testimony under cross-examination where she “conceded she did not issue a bilateral modification creating separate completion dates” (app. reply at 18).

The cited pages do not support the factual contention for which they were cited because volume five of the hearing transcript ends on page 116. DECISION AI is known to “hallucinate” fictitious cases It is now well known that AI platforms can generate non-existent cases. See Sanders v.

Cl. 163, 168-170 (2025) (“It is no secret that generative AI programs are known to ‘hallucinate’ non-existent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs.”); Benjamin v. Costco Wholesale Corp., 779 F.

2025) (stating that while “AI tools can make legal work more efficient, they also can ‘hallucinate’ – that is, they produce blatantly incorrect information that, on its face, appears truthful.”). These hallucinated cases provide the outward appearance of real judicial decisions, because they include indicia such as case names and docket numbers, real case reporters with DOCUMENT FOR PUBLIC RELEASE. The decision issued on the date below is subject to an ASBCA Protective Order.

8 page numbers and pin cites, real courts and judges who practice before those courts, provide dates on which a decision was purportedly issued, etc. Some or all these markers of real cases may be fictitious. See e.g., United States v.

What the text mentions

Pattern matches on the documents' text. Each line is a fact that the text contains the words, not a finding about the case.

Where this fits

This page is a record, not legal advice. It quotes the documents on file and lists what their text mentions. Read the decision at the source before relying on it, and check whether a later order changed it.

More from Armed Services Board of Contract Appeals, from Federal, or from 2025. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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