Arizona federal court: attorney sanctioned for AI-fabricated citations — only 5 to 7 of 19 cases were real, pro hac vice revoked, no fine

The problem

Argelia Esther Mavy appealed a denied Social Security disability claim in the U.S. District Court for the District of Arizona. Her attorney, Maren Ann-Miller Bam (Salus Law PLLC, Richland, WA), appearing pro hac vice, filed an Opening Brief that Magistrate Judge Alison S. Bachus found “replete with citation-related deficiencies, including those consistent with artificial intelligence generated hallucinations” source. Reviewing the brief, the court determined that “of the 19 instances of citations included in Plaintiff’s Opening Brief, 5 to 7 of those cases exist and appear as quoted or generally stand for the proposition for which they are cited” source — meaning “well over the majority” were fabricated, misleading, or unsupported, with three fictitious cases attributed to three real Arizona federal judges. AZ Big Media put the same finding as its complement: “12 of the 19 cases cited were ‘fabricated, misleading, or unsupported’” source. PPC Land independently reported that “of 19 case citations in Bam’s opening brief, only 5 to 7 cases existed and supported the propositions for which they were cited” source.

What was built

No system was built or deployed. This is an AI-governance honest-negative drawn from a court’s own record. Notably, the court did not make a factual finding that generative AI was actually used: “Counsel has not explicitly admitted to using AI to prepare her Opening Brief,” and her own filing described the three non-existent cases as “[l]ikely fabricated by artificial intelligence” source. The court held such a finding was unnecessary — citing nonexistent case law is a false statement to the court regardless of source — but found the brief bore “all the markings of a hallucinated case created by” AI source. No specific AI product is named in the order.

The outcome

Magistrate Judge Bachus imposed Rule 11 sanctions that were entirely non-monetary — a set the ABA Journal described as “the toughest of the penalties I’ve seen so far” for AI hallucinations source. The court: (1) revoked Bam’s pro hac vice status and removed her from the case; (2) struck the Opening Brief; (3) ordered her to serve the order on her client; (4) ordered her to “write a letter to the three Judges to whom she attributed fictitious cases, Hon. Douglas L. Rayes, Hon. Michael T. Liburdi, and Hon. John Z. Boyle,” notifying them of her use of fake cases with their names attached; (5) ordered her to transmit the order to every judge before whom she is attorney of record; and (6) directed that “the 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” source. ABA Journal reported the same package firsthand — the court “revoked an attorney’s pro hac vice status, removed her as counsel of record for her client, struck her opening brief with faulty citations” source, and PPC Land confirmed “the court revoked Bam’s pro hac vice status and removed her from the case entirely” source. The court declined to impose any monetary sanction.

The appeal

Bam told the ABA Journal she “will appeal the sanctions,” calling the ruling one that “sets an impossibly high, and frankly unworkable, standard for every practicing attorney” source. Because that appeal is pending, the sanction is not yet final.

A note on the weakest link

The critical facts — the “5 to 7 of 19 exist” finding and the six-part non-monetary sanctions list — rest on the strongest possible source, the Arizona court’s own signed order (Tier 1), byte-tied to the govinfo USCOURTS package, so the three newsrooms only corroborate; they are not load-bearing. The genuinely weak link is the appeal posture: that Bam intends to appeal and her “impossibly high, and frankly unworkable” characterization come from a single independent source (ABA Journal, Tier 2), not the primary record — and that is precisely why this page cannot be green. The sanction is not final while the appeal is live. One apparent discrepancy is not a conflict: AZ Big Media’s “12 of the 19 cases cited were fabricated” is the arithmetic complement of the court’s “5 to 7 of those cases exist,” not a competing count.

How this was verified

• Method: Tier-1 court-origin order (No. CV-25-00689-PHX-KML, Doc. 18; 2025 WL 2355222, signed Aug. 14, 2025, Bachus, M.J.), byte-tied to the govinfo USCOURTS package PDF (USCOURTS-azd-2_25-cv-00689-0.pdf, 393,604 bytes; sha1-b32 7QF6MQO6BKSJGNETRNS6FR42VPVHOUCE). Every quoted line was re-matched against the pdf-parse extraction of that package.
• Corroboration: the critical claims (only 5 to 7 of 19 citations real; the six-part non-monetary sanction) are carried firsthand by three independent newsrooms — PPC Land (Luis Rijo), AZ Big Media (Tufan Neupane), and ABA Journal (Debra Cassens Weiss) — all re-fetched and re-matched this session. The court is the independent origin and is not counted as a secondary.
• Date verified: checker round 1, 2026-08-05 (confidence 1.000; graduated to pending).
• What “verified” (green) would still require: a human confirming on the D. Ariz. docket (No. CV-25-00689-PHX-KML) that the Aug. 14, 2025 order stands as final — counsel states she will appeal, so it is not — plus any Washington State Bar Association disciplinary outcome. Green never depends on the sanctioned attorney confirming anything. This page is pending (amber); no green badge is claimed.

Related case files

• In re Nwaubani (4th Cir.) — another appellate discipline case where the court declined to decide whether AI was actually used and imposed only a non-monetary sanction; the closest sibling to Arizona’s “regardless of source” reasoning.
• United States v. Hayes — the same “court declines to find AI use” family: a fictitious citation sanctioned while the court expressly declined to hold AI was the cause.
• Romero v. Corona Investments (7th Cir.) — the mirror-image outcome: an appeals court confronting “hallucinated citations” that declined to sanction at all, where Arizona instead imposed the “toughest of the penalties.”

Sources

1. U.S. District Court for the District of Arizona · Mavy v. Commissioner of Social Security Administration, No. CV-25-00689-PHX-KML, Order (Doc. 18; 2025 WL 2355222) · 2025-08-14 · https://www.govinfo.gov/content/pkg/USCOURTS-azd-2_25-cv-00689/pdf/USCOURTS-azd-2_25-cv-00689-0.pdf — Tier 1 (primary, signed sanctions order; independent-origin, not counted toward corroboration; byte-tied to the govinfo USCOURTS package, sha1-b32 7QF6MQO6BKSJGNETRNS6FR42VPVHOUCE).
2. PPC Land (Luis Rijo) · “Arizona court sanctions lawyer for AI-generated false citations” · 2025-08-15 · https://ppc.land/arizona-court-sanctions-lawyer-for-ai-generated-false-citations/ — Tier 2 (independent newsroom carrying the “5 to 7 of 19” finding and the pro-hac-vice revocation firsthand).
3. AZ Big Media (Tufan Neupane) · “Here’s how AI-driven hallucinatory filings are impacting Arizona courts” · 2025-11-05 · https://azbigmedia.com/business/heres-how-ai-driven-hallucinatory-filings-are-impacting-arizona-courts/ — Tier 2 (independent newsroom; states the complement “12 of the 19 cases cited were fabricated, misleading, or unsupported” and the “replete with citation-related deficiencies” language).
4. ABA Journal (Debra Cassens Weiss) · “Court rejects monetary sanctions for AI-generated fake cases, citing lawyer’s tragic personal circumstances” · 2025-08-19 · https://www.abajournal.com/web/article/court-rejects-monetary-sanctions-for-ai-generated-fake-cases-citing-lawyers-tragic-personal-circumstances — Tier 2 (independent newsroom; the sole source for the appeal posture and “impossibly high, and frankly unworkable” quote, and the “toughest of the penalties” characterization).