DECISION REGARDING SANCTIONS:  February 24, 2026
CBCA 7992, 7993
LOUIS J. BLAZY,
Appellant,
v.
DEPARTMENT OF STATE,
Respondent.
Louis J. Blazy, pro se, Alexandria, VA.
Alexandra N. Wilson, Office of the Legal Adviser, Buildings and Acquisitions,
Department of State, Washington, DC, counsel for Respondent.
Before Board Judges GOODMAN, KULLBERG, and CHADWICK.
GOODMAN, Board Judge.
Appellant, Louis J. Blazy, filed a motion in these consolidated appeals titled “Motion
For Procedural Determination on the Validity of the Contracting Officer’s Final Decisions
and Stay Merits Proceeding” (appellant’s motion).  We deny the motion in a decision issued
concurrently with this decision.  Here, the panel, sua sponte, issues a sanction in response to
appellant’s misconduct with regard to his motion’s content.


CBCA 7992, 7993 2
Background
Appellant’s Sanctionable Misconduct
Citations to Non-Existent Decisions
Appellant’s motion contained four citations to decisions that appeared not to exist. 
For each citation, the Board issued an order directing appellant to produce a copy of the
decision.  Appellant did not submit copies of the requested decisions because those decisions,
upon which he relied, do not exist.  Appellant offered general, unpersuasive, confusing, and
vague explanations for why he cited the non-existent decisions.  He stated that “certain legal
research databases . . . may not fully integrate with the . . . search codes used by the Court
of Federal Claims.”  He referred to errors in “publicly available sources,” “editorial errors”
in unnamed “secondary reference sources,” and “mistakes in [unidentified] commercial
contract law digests, and training compilations.”  In one instance, appellant stated that a
non-existent citation was used as “shorthand” for the citation of another case which he
offered as a substitute, without explaining his definition of “shorthand” or how such
“shorthand” translated to a citation for another decision.
In another instance, appellant submitted what he characterized as an existing
“decision,” stating that it was the decision that he intended to submit for one of the
non-existing decisions.  The existing “decision” submitted was a dismissal order that
contained no substantive information as to the nature of the case, which appellant asserted
stood for a legal principle, which principle was in no way discernible from the text of the
dismissal order.  In another instance, appellant submitted an existing decision, again stating
that it was a substitute for a non-existing decision which he cited.  That case did not stand
for the principle cited.
Appellant submitted a general, non-specific explanation of his search method and a
list of databases and indexes that he searched.  At no time did he state that he had actually
read any of the cases cited or identify in which source any of the citations to the non-existent
decisions were found.  Appellant’s explanation for citing the non-existent decisions offered
no other detail, screen shots, or copies of any portions of the resources which specifically
contained the citations of the non-existent decisions.

CBCA 7992, 7993 3
Quoting Non-Existent Deposition Dialogue
Appellant’s motion contained four excerpts from depositions in quotation marks,
appearing to be direct quotations, with deposition transcript page numbers cited.1 
Respondent’s response to appellant’s motion noted that the quoted language did not exist on
the pages cited or anywhere in the deposition transcripts.  The Board issued an order
directing appellant to state if the quotations were direct quotations or constructed from
testimony.  If they were constructed quotations, the Board directed appellant to quote the
deposition testimony from which he created the construction, with transcript page citations.
Appellant responded that the four quotes were constructed and quoted deposition
testimony from which he alleges he constructed the quotes.  The transcript page numbers
where the quoted testimony appears do not correspond to the transcript page numbers initially
cited for the four quotations in appellant’s motion.  The actual testimony quoted does not
support the non-existent “direct” quotes in the motion.
Discussion
Appellant represents himself as pro se.  “We construe a pro se litigant’s pleadings
liberally,” but such lenience does not affect “a pro se litigant’s burden of proof or our
[assessment] of the factual record.”  House of Joy Transitional Programs v. Social Security
Administration, CBCA 2535, 12-1 BCA ¶ 34,991, at 171,975 (citing Haines v. Kerner, 404
U.S. 519, 520 (1972); Greenlee Construction, Inc. v. General Services Administration,
CBCA 416, 07-1 BCA ¶ 33,514, at 166,062).
The lenience afforded to pro se litigants does not relieve appellant of a fundamental
standard of conduct for all litigants—the duty of candor to the tribunal.  O’Brien v. Flick, No.
24-61529-CIV, 2025 WL 242924, at *5 (S.D. Fla. Jan. 10, 2025).  The duty of candor to a
tribunal requires that all submissions be accurate, complete, and truthful.  The violation of
this duty is misconduct which affects the Board’s process and proceedings and is
sanctionable pursuant to Board Rule 35, which reads in relevant part:
(a)  Standards of conduct.  All parties and their representatives, . . . shall obey
directions and orders of the Board and adhere to standards of conduct
applicable to such parties and persons.
1 The depositions are subject to a protective order.  We do not discuss the
protected material in this decision.

CBCA 7992, 7993 4
(b)  Sanctions.  If a party . . . fails to comply with any direction or order of the
Board (including an order to provide or permit discovery) or engages in
misconduct affecting the Board, its process, or its proceedings, the Board may
make such orders as are just, including the imposition of appropriate sanctions.
41 CFR 6101.35 (2024) (emphasis added).
The Board issued seven orders with inquiries to appellant with regard to the
information which is the subject of this decision.  While appellant stated that his responses
were offered to “clarify” the submission of the information at issue, the vagueness of his
responses only created additional confusion and failed to credibly explain how such non-
existent and misleading information could have been submitted.  Appellant did not express
an apology to the Board in any of his responses but maintained that the information was
submitted “in good faith” and resulted in “harmless error.”  Appellant’s actions did not result
in “harmless error.”  Rather, the results of appellant’s actions are as follows:
(1) Appellant’s submission of citations to non-existent decisions, quoting
non-existent deposition language, and mischaracterizing existing deposition
language violates appellant’s duty of candor to the Board.2
(2) Appellant’s actions in (1) above constitute misconduct, which violate
Board Rule 35, as they affect the Board, its process, and its proceedings, 
resulting in (a) the waste of the Board’s and opposing counsel’s resources to
determine the validity and accuracy of information submitted by appellant; 
and (b) excessive time and effort, and delay, for the panel to deliberate and to
resolve appellant’s motion.
(3) Appellant’s vague, confusing, and unpersuasive responses to the
Board’s orders raise questions as to the credibility and veracity of his
responses.
2 In response to a Board order, appellant stated that he did not use artificial
intelligence (AI) to draft his motion.  A characteristic of using AI is its propensity to
“hallucinate,” meaning to create information which appears credible and real but which is
actually false, non-existent, or a mischaracterization of existing information.  There is no
prohibition against using AI at the Board.  However, “[i]f using AI, parties retain full
responsibility for the accuracy of all submissions to the Board.”  Annual Report, United
States Civilian Board of Contract Appeals, Fiscal Year 2025, 
https://cbca.gov/files/2025-CBCA-Annual-Report.pdf (last visited February 23, 2026).  

CBCA 7992, 7993 5
Sanction
Appellant’s actions as described herein constitute sanctionable misconduct pursuant
to Board Rule 35.  We issue this formal admonishment to appellant to alert appellant that,
as the case proceeds, if he continues such conduct, additional and harsher sanctions will be
imposed, which could include dismissal of the appeals without proceeding to the merits. 
Rule 35(b)(6).
    Allan H. Goodman        
ALLAN H. GOODMAN
Board Judge
We concur:
    H. Chuck Kullberg             Kyle Chadwick                
H. CHUCK KULLBERG KYLE CHADWICK
Board Judge Board Judge