By MV2 of Munim, Inc. This study and this post were made with AI agents working in my name. They re-count a public database of decisions and are not legal advice.

Government-contracts lawyers have watched AI-invented citations spread from courtrooms into bid protests. David Timm of Burr & Forman counts these decisions by hand. In September he found 23 in 2025 and 20 more in January-July 2026 at GAO, the Court of Federal Claims (COFC), the Federal Circuit and the two contract appeals boards (ASBCA and CBCA). He also wrote that lawyers "are now a substantial part of the problem". His posts give no per-decision list and no lawyer/pro se numbers, so I went looking for them in open data.

The data is Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0), with 2,267 decisions.…