Mavy v. Commissioner of Social Security Administration
D. Arizona · Jan 13, 2026
What happened in this matter?
The court vacated the Rule 11 sanctions finding, ruling that the attorney's conduct, while reckless and careless, did not meet the 'bad faith' threshold required for sua sponte sanctions. Nevertheless, the court upheld the revocation of the attorney's pro hac vice status and the striking of the brief, citing the need to promote the orderly administration of justice.
- Why the court cared
- False Quotes: Case Law | Cited district court decision Hobbs does not exist. || Fabricated: Case Law | Lubin was quoted as forbidding ALJs from disregarding moderate CPP limitations without explanation; that language is not in Lubin. || False Quotes: Case Law | Garrison was cited as holding ALJs must connect symptoms to functional limitations in the RFC; no such express holding appears at p. 1017. || Misrepresented: Case Law | Garrison was quoted with an added phrase not in the case; only the first portion (as a parenthetical to a Seventh Circuit case) appears, the latter part does not. || Misrepresented: Case Law | Lingenfelter was quoted as stating narcotic pain treatment is not inconsistent with disabling pain testimony; no such quote exists. || False Quotes: Case Law | Trevizo was cited as requiring consideration of waxing and waning impairments; the case contains no such discussion or requirement. || False Quotes: Case Law | Revels was quoted as saying fibromyalgia symptoms are 'entirely subjective' and must be evaluated accordingly; that language does not appear in Revels. || Misrepresented: Case Law | Garrison was cited for a requirement that the RFC reflect all impairments in combination; p. 1016 does not contain such a requirement. || Misrepresented: Case Law | Barrett was cited (and mislabeled as Ninth Circuit) for remand due to obesity’s impact on fibromyalgia/DDD; the case does not mention obesity, fibromyalgia, or disc disease. || Misrepresented: Case Law | Orn was cited as requiring the ALJ to explain how impairments are accommodated in the RFC; no such requirement appears at p. 639. || False Quotes: Case Law | Revels was attributed the quote that fibromyalgia symptoms are entirely subjective and have no lab tests; that quoted language does not appear in Revels. || Misrepresented: Case Law | Brink was cited for simple, routine tasks limits; the quoted phrase is slightly different and the proposition is inapposite. || Fabricated: Case Law | Cited district court decision Brown v. Colvin does not exist. || Fabricated: Case Law | Cited district court decision Wofford v. Berryhill does not exist.
- Why it matters now
- Rule 11 violations with fake cases trigger pro hac vice revocation and multi-state bar referrals; no tool pedigree saves you.
Why this matter is tracked
False Quotes: Case Law | Cited district court decision Hobbs does not exist. Outcome: Revocation of pro hac vice status, striking of the brief. In an earlier order, following Show Cause proceedings, a magistrate determined that the counsel violated Rule 11(b)(2) by failing to verify the accuracy of the citations and imposed several sanctions:"The pro hac vice status of Counsel shall be revoked and Counsel will be removed from this case;Plaintiff’s Opening Brief shall be stricken;Counsel will be ordered to promptly serve a copy of this Order on Plaintiff, who will in turn be afforded time to engage new counsel or proceed as a self-represented litigant;Counsel will be ordered to write a letter to the three Judges to whom she attributed fictitious cases, [...], notifying them of her use of fake cases with their respective names attached;Counsel will be ordered to transmit a copy of this Order to every Judge who presides over any case in which Counsel is attorney of record; andThe Clerk of Court’s Office will be directed to serve a copy of this Order on the Washington State Bar Association, of which Counsel is a member. If Counsel is a member of any other state’s bar, she shall serve a copy of this Order on that state’s bar office."The court later reversed all sanctions, but reinstated the first and second on other grounds.
Rule 11 violations with fake cases trigger pro hac vice revocation and multi-state bar referrals; no tool pedigree saves you.
Record details
What the record establishes about AI use
The magistrate judge noted the brief's citations suggested the use of artificial intelligence.
The district court reviewed a magistrate judge's order imposing Rule 11 sanctions following the attorney's motion for reconsideration and extension of time.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
14 citation, quotation, or authority issues are recorded in the source dataset.
- False Quotes: Case Law | Cited district court decision Hobbs does not exist.
- Fabricated: Case Law | Lubin was quoted as forbidding ALJs from disregarding moderate CPP limitations without explanation; that language is not in Lubin.
- False Quotes: Case Law | Garrison was cited as holding ALJs must connect symptoms to functional limitations in the RFC; no such express holding appears at p. 1017.
- Misrepresented: Case Law | Garrison was quoted with an added phrase not in the case; only the first portion (as a parenthetical to a Seventh Circuit case) appears, the latter part does not.
- Misrepresented: Case Law | Lingenfelter was quoted as stating narcotic pain treatment is not inconsistent with disabling pain testimony; no such quote exists.
- False Quotes: Case Law | Trevizo was cited as requiring consideration of waxing and waning impairments; the case contains no such discussion or requirement.
- False Quotes: Case Law | Revels was quoted as saying fibromyalgia symptoms are 'entirely subjective' and must be evaluated accordingly; that language does not appear in Revels.
- Misrepresented: Case Law | Garrison was cited for a requirement that the RFC reflect all impairments in combination; p. 1016 does not contain such a requirement.
Show 6 additional discrepancies
- Misrepresented: Case Law | Barrett was cited (and mislabeled as Ninth Circuit) for remand due to obesity’s impact on fibromyalgia/DDD; the case does not mention obesity, fibromyalgia, or disc disease.
- Misrepresented: Case Law | Orn was cited as requiring the ALJ to explain how impairments are accommodated in the RFC; no such requirement appears at p. 639.
- False Quotes: Case Law | Revels was attributed the quote that fibromyalgia symptoms are entirely subjective and have no lab tests; that quoted language does not appear in Revels.
- Misrepresented: Case Law | Brink was cited for simple, routine tasks limits; the quoted phrase is slightly different and the proposition is inapposite.
- Fabricated: Case Law | Cited district court decision Brown v. Colvin does not exist.
- Fabricated: Case Law | Cited district court decision Wofford v. Berryhill does not exist.
Questions this record answers
- What happened in Mavy v. Commissioner of Social Security Administration?
- The court vacated the Rule 11 sanctions finding, ruling that the attorney's conduct, while reckless and careless, did not meet the 'bad faith' threshold required for sua sponte sanctions. Nevertheless, the court upheld the revocation of the attorney's pro hac vice status and the striking of the brief, citing the need to promote the orderly administration of justice.
- Why does Mavy v. Commissioner of Social Security Administration matter for legal AI risk?
- Rule 11 violations with fake cases trigger pro hac vice revocation and multi-state bar referrals; no tool pedigree saves you.
- What does the public record establish about Mavy v. Commissioner of Social Security Administration?
- 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.
- Which source supports this Mavy v. Commissioner of Social Security Administration summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.