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Mavy v. Commissioner of Social Security Administration

Court
D. Arizona
Jurisdiction
USA
Decided
2026-01-13
AI tool
Implied
Outcome
Revocation of pro hac vice status, striking of the brief
Monetary penalty
None reported

What was hallucinated

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.

Details

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.

Sanction teardown · D. Arizona, USA · 2026-01-13

Mavy v. Commissioner of Social Security Administration

What happened

In D. Arizona, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • 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.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Revocation of pro hac vice status, striking of the brief

Additional detail

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.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/1309/Mavy_v._Commissionner_USA_13_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1309/Mavy_v._Commissionner_USA_13_January_2026.pdf

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