Mission Critical Project Services, Inc.
U.S. Government Accountability Office · GAO
Verified April 26, 2026
- Citation
- Mission Critical Project Servs., Inc., B-424081.2, Mar. 26, 2026 (Comp. Gen.)
- Decided
- March 26, 2026
Summary
Mission Critical Project Services (MCPS), represented pro se by Ryan Franz and Emily Franz, filed a bid protest challenging an Air Force HVAC contract award. After the agency moved to dismiss, MCPS cited cases in its response, and when GAO requested copies the protester produced filings with mismatched citation information, cases that did not stand for the propositions asserted, and non-existent decisions. GAO (decision authored under General Counsel Edda Emmanuelli Perez) found the erroneous citations bore "the hallmarks of the use of a large-language model or other artificial intelligence (AI) without adequate verification."
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Protest denied in part and dismissed in part on the merits (untimely revised quotation, brand-name technical unacceptability). No monetary penalty imposed for the AI-generated citations, but GAO issued an explicit warning that "any future submission of filings with citations to non-existent authority may, after a review of the totality of the circumstances, result in the imposition of sanctions."
Why does Mission Critical Project Services, Inc. matter for law firms using AI?
Mission Critical is one of a growing line of GAO bid-protest decisions (following Raven Investigations and KE Systems Services) putting government contractors on notice that AI-generated citations will be flagged and may draw sanctions in future filings. For a managing partner whose firm advises federal contractors, the lesson is that the duty to verify generative-AI output extends beyond Article III courts to administrative tribunals: GAO has now expressly reserved its inherent authority to dismiss protests and sanction parties who file fabricated authority, even when the protester appears pro se.
Sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.