Matter of: Bramstedt Surgical Inc.
GAO · Jan 28, 2026
- Jurisdiction
- federal
- Court
- GAO
- Record ID
- matter-of-bramstedt-surgical-inc-2026-01-28
- Observed outcome
- Protest dismissed; formal warning issued to the protester regarding the submission of inaccurate citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The GAO issued a formal warning to the protester for submitting filings containing fabricated and inaccurate legal citations. The tribunal explicitly attributed these errors to the use of AI tools without adequate attorney supervision or verification, cautioning that future submissions of non-existent authority may result in the imposition of sanctions.
Fabricated: Case Law | Protester cited a non-existent decision combination (party name, B-number, and date) that GAO could not locate. || Fabricated: Case Law | Protester cited a partially accurate citation (party name and B-number exist but date/matter do not match the cited proposition). || Fabricated: Case Law | Protester cited a B-number/party combination GAO could not locate and that was irrelevant to the asserted timeliness principle. || 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. || 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. || 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. || Fabricated: Case Law | Appendix included four additional GAO decisions with inaccurate citations that the protester later withdrew reliance on.
GAO protests are not a low-stakes venue; invalid B-number citations will surface and torch your credibility with the tribunal.
Failure modes and consequences
- Fake Citations
- Administrative
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- Large-language model or other artificial intelligence (AI)
- Known monetary consequence
- Not recorded
- Procedural posture
- Bid protest dismissed by the GAO for failure to state a legally sufficient basis of protest, with a concurrent warning issued regarding the submission of inaccurate citations.
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
The GAO identified the use of a large-language model or AI.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Retain a matter-level record of source checks and corrections.