Mavy v. Commissioner of Social Security Administration

What sanction did the court impose?

Rule 11 violation finding vacated. Four of six sanctions vacated, including the requirement that Bam notify her client, write letters to three Arizona judges whose names had been attached to fictitious cases, send the order to every judge presiding over her other cases, and referral to the Washington State Bar Association. The order striking the opening brief and revoking Bam's pro hac vice status in this case was upheld on the alternative ground that pro hac vice admission may be revoked for conduct impairing the orderly administration of justice, a standard that does not require bad faith. No monetary sanction.

Why does Mavy v. Commissioner of Social Security Administration matter for law firms using AI?

Mavy is a useful counterpoint to the Mata line of cases for managing partners thinking about supervisory liability. The sanctioned lawyer was not the drafter, had circulated an explicit anti-AI advisory to contract attorneys, and operated a two-layer review process; the district court still found her conduct reflected recklessness and revoked her pro hac vice admission, but vacated Rule 11 and the home-state bar referral because the record did not support the heightened “tantamount to bad faith” standard required for sua sponte sanctions. The case also illustrates that a paper review process which fails to detect fabricated citations is treated as a rubber stamp, and that pro hac vice status can be lost on a careless-administration-of-justice standard well short of bad faith.