Appeals of Huffman Construction, LLC
ASBCA · Oct 23, 2025
- Jurisdiction
- federal
- Court
- ASBCA
- Record ID
- appeals-of-huffman-construction-llc-2025-10-23
- Observed outcome
- The Board granted the government's motion and struck the reply brief in its entirety.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The ASBCA struck the contractor's reply brief in its entirety as a sanction for submitting a filing where over 70% of citations were inaccurate, including AI-generated hallucinations and fabricated transcript references. The Board determined that counsel's failure to verify the AI-generated content violated the duty of reasonable inquiry, regardless of the internal review safeguards claimed by the firm.
The Board reasoned that under Rule 11-type standards, attorneys have an affirmative duty to conduct a reasonable inquiry into the facts and law before filing. It found that the 'pure heart, empty head' defense was insufficient, as the sheer volume of errors (over 70%) demonstrated a failure of diligence that rendered the brief nonsensical and wasted judicial resources.
Over 70% bad citations gets a brief struck wholesale; run a 100% citation audit before any AI-drafted filing leaves the firm.
Failure modes and consequences
- Fabricated Case Law
- Misrepresented Case Law
- Fabricated Transcript Citations
- Misrepresented Exhibits And Submissions
- Failure Of Human In The Loop Verification
- Fake Citations
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- The Board issued a non-dispositive decision granting the government's motion to strike the appellant's post-hearing reply brief.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Counsel admitted to using AI technology to assist in drafting.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement a mandatory 100% verification audit for all AI-generated citations against primary source documents.
- Establish a formal protocol for verifying transcript and record citations that does not rely on the same AI tool used for drafting.
- Document the specific verification steps taken by human reviewers to demonstrate reasonable inquiry under Rule 11 standards.