Was DSME Construction Co., Ltd. sanctioned over AI-generated citations?

DSME Construction Co., Ltd. (ASBCA, March 13, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Surreply at issue; sanctions decision on AI-generated citations. No monetary penalty in this order.

Which AI tool was involved in DSME Construction Co., Ltd.?

The order in DSME Construction Co., Ltd. does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

March 13, 2026 · AI sanctions database

DSME Construction Co., Ltd.

DSME Construction Co., Ltd. is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: ASBCA
Date: March 13, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Surreply at issue; sanctions decision on AI-generated citations
Penalty: No monetary penalty in this order.

What the record shows

The government moved to strike appellant's surreply and to dismiss the appeal as a sanction, asserting the surreply contained numerous citations to cases that do not exist, which it described as hallmarks of generative AI. Appellant admitted referencing ten non-existent cases across three briefs (eight in the surreply) and characterized them as an unintentional lapse without explaining how they occurred.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · ASBCA

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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