Mavy v. Commissioner of Social Security Administration
D. Arizona · Jan 13, 2026
- Jurisdiction
- federal
- Court
- D. Arizona
- Record ID
- mavy-v-commissioner-of-social-security-administration-2026-01-13
- Observed outcome
- The Rule 11 violation finding was vacated; the revocation of pro hac vice status and the striking of the opening brief were upheld.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Rule 11 violations with fake cases trigger pro hac vice revocation and multi-state bar referrals; no tool pedigree saves you.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Administrative
- Trial
- Professional
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The district court reviewed a magistrate judge's order imposing Rule 11 sanctions following the attorney's motion for reconsideration and extension of time.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The magistrate judge noted the brief's citations suggested the use of artificial intelligence.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Assign a responsible reviewer for AI-assisted research and drafting.
- Set a written rule for permissible AI use and mandatory verification.
- Escalate and correct a suspect filing promptly, with a documented response.