The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.
Docket entry 47, 13 January 2026 · source · PDF · 15 pages
Docket text. ORDER granting 35 Motion for Extension of Time and 37 Second Motion for Reconsideration. The Order imposing Rule 11 sanctions (Doc. 18 ) is VACATED except the opening brief remains stricken and attorney Maren Bam's pro hac vice status remains revoked for purposes of this case. All other matters remain referred to the magistrate judge. The Clerk shall forward a copy of this order to the Court of Appeals for the Ninth Circuit, referencing Case Number 25-6248. Signed by Judge Krissa M Lanham on 1/13/26. (DXD) (Entered: 01/13/2026)
17-8). It is undisputed the opening brief was filed despite it s non-existent citations and that Bam was the only attorney who signed it. On receiving the magistrate judge’s order identifying the citation errors , Bam “initiated a thorough internal review of the brief . . . as well as other work submitted by [the same] contract writer.” (Doc.
17 at 6.) Despite acknowledging the errors were “deeply concerning and contrary to the standard of advocacy [Bam’s] firm strives to uphold,” Bam stated she had not “knowingly submitted false or non -existent citations” and did not “intend to mislead the Court or submit citations not grounded in valid legal authority.” (Doc. 17 at 1, 5.) On August 14, 2025, the magistrate judge ruled Bam had violated Rule 11 by filing the opening brief with incorrect and hallucinated citations. (Doc.
(Doc. 18.) In reaching that conclusion, the magistrate judge found “well over the majority of the citations” in the opening brief “were fabricated, misleading, or unsupported.” (Doc. 18 at 9.) Based on the number of errors, it was “apparent to [the magistrate judge] that [Bam] did not review the citations.” (Doc.
2001)).) In that context, sanctions are permissible only “in situations that are akin to a contempt of court.” (Doc. 1 8 at 13 (citations omitted).) According to the magistrate judge, t hat “akin to a contempt” standard was satisfied because the opening brief was “riddled with fabricated, misleading, or unsupported citations” such that without them, “entire sections of the [brief’s] ‘Analysis’ [were] nearly wholly unsupported, and clearly, there was no reasonable inquiry made into its contents.” (Doc. 18 at 14.) The second critical aspect of the magistrate judge’s sanctions order is an explicit finding that Bam had not acted in subjective bad faith.
Requiring Bam provide her client with a copy of the sanctions order; 4. Requiring Bam “write a letter to the three [District of Arizona] Judges to whom she attributed fictitious cases . . . notifying them of her use of fake cases with their respective names attached”; 5. Requiring Bam send a copy of the sanctions order “ to every Judge who presides over any case in which [Bam] is attorney of record”; and 6.
There is - 13 - no dispute that process broke down here, raising significant concerns that Bam’s internal review process was so cursory as to amount to a rubber stamp. A system that does not detect failures of the magnitude reflected in the opening brief must be redesigned , particularly with Bam now on notice that she risks sanctions if she files future briefs containing hallucinated citations. See Mata v.
3d 443, 464 (S.D.N.Y. 2023) (finding subjective bad faith where attorneys continued to cite hallucinated cases after court order notif ied them of hallucinated cases). But warning the attorney not to use artificial intelligence and subjecting the brief to two layers of review would ordinarily be reasonable precautions for an attorney not already on notice that her firm’s review structure and practices were flawed , and not “outrageously improper, unprofessional and unethical” so as to support a “tantamount to bad faith” finding.
City of Long Beach, 96 F.4th 1255, 1256 (9th Cir. 2024) (striking in entirety opening brief containing fabricated case law). - 15 - Accordingly, IT IS ORDERED the Motion for Extension of Time (Doc. 35) is GRANTED.
Docket entry 18, 14 August 2025 · source · PDF · 24 pages
Docket text. **Partially Vacated per Order (Doc. 47 )** ORDER finding Counsel Maren Bam has violated Rule 11 of the Federal Rules of Civil Procedure and imposing sanctions. The pro hac vice status of Counsel Maren Bam is revoked, and Counsel Maren Bam is removed as counsel of record for Plaintiff in this matter. Plaintiff's Opening Brief (Doc. 13 ) shall be stricken. No later than 3 business days from the date of this Order, Counsel shall serve a copy of this Order on Plaintiff. No later than 10 business days from the date of this Order, Counsel shall transmit a letter to each of the three Judges to whom she attributed fictitious cases in her Opening Brief. No later than 10 business days from the date of this Order, Counsel shall transmit a copy of this Order to every Judge who presides over any case in which Counsel is attorney of record. The Clerk shall 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 no later than 10 business days from the date this Order is entered. Counsel shall file a certification with this Court within 14 business days from the date of this Order, affirming Counsel has complied with Sanctions 3 through 6 above. Failure to timely comply with this Order may result in further sanctions. Within 45 days from the date Plaintiff is served with a copy of this Order, Plaintiff's new counsel shall file a Notice of Appearance, or if Plaintiff wishes to represent herself, Plaintiff shall file a Notice with the Court stating that she will proceed as a self-represented party. The Court will issue an amended scheduling order after receiving that Notice. Signed by Magistrate Judge Alison S Bachus on 8/14/25. (DXD) Modified on 1/13/2026 (DXD). (Entered: 08/14/2025)
(Doc. 16.) The Court did so because the Opening Brief was replete with citation-related deficiencies , including those consistent with artificial intelligence generated hallucinations. The Court ordered Plaintiff’s counsel, Maren Bam, to show good cause as to why sanctions should not result.
15.) No Reply followed. During its review of the Opening Brief, the Court discovered that the majority of - 2 - the cases cited by Plaintiff in her Opening Brief either did not exist, did not support the proposition for which they were cited, or misquoted or miscited the authority. It appeared to the Court that at least some of the purported cases were artificial intelligence hallucinations.
Cal. 2025) (identifying “the markings of a hallucinated case created by generative artificial intelligence (AI) tools,” including case names that appear to be real bu t do not exist, and actual courts and dates). This Court issued its Order to Show Cause and directed Plaintiff’s counsel to show good cause as to why sanctions should not issue under Rule 11 of the Federal Rules of Civil Procedure and this Court’s Rules of Practice and Procedure (“Local Rules” or “LRCiv” ).
17-3.) The announcement stated: This bulletin serves as a critical reminder to all litigants of their obligations under Rule 11 of the Federal Rules of Civil Procedure to ensure all legal contentions are warranted by existing law, especially in light of the increasing use of AI in preparing motions and other filings. While acknowledging the potential benefits of AI, the Court has observed instances of AI-generated arguments and citations to non-existent cases, a practice that is strictly prohibited and may result in sanctions to uphold the integrity of the judicial system. (Doc.
N.M. May 9, 2025) (same where use of fictitious citations occurred). This Order is not dispositive of this case. - 6 - III.
2017) Case exists. Quoted language does not exist in case. Counsel writes that in Revels, “ the court held that fibromyalgia symptoms are ‘entirely subjective ’ and must be evaluated accordingly .” Although Revels discusses at length consideration of evidence in fibromyalgia cases, and thus the proposition is generally correct, Revels contains no such quoted language.
Ariz. July 21, 2021) Case does not exist. 13 20 Lingenfelter v.
2007) Case exists. Quoted language does not exist in case. Counsel writes that the 9th Circuit stated in Lingenfelter: “The fact that a claimant’s pain is treated with narcotic medication is not inconsistent with his testimony of disabling pain.” No such quote is found in Lingenfelter.
Docket entry 16, 22 July 2025 · source · PDF · 4 pages
Docket text. ORDER TO SHOW CAUSE - Within 10 days from the date of this Order, Plaintiff's counsel shall show cause why the Court should not impose sanctions under Rule 11 of the Federal Rules of Civil Procedure for submitting non-existent cases and otherwise deficient case law citations to the Court. Signed by Magistrate Judge Alison S Bachus on 7/22/25. (DXD) (Entered: 07/22/2025)
The Court is unable to locate three of the cases cited by Plaintiff in her Opening Brief. In addition to the non-existent cases, the Court found misquoted language, quotations that do not appear in the cited cases at all, and cases that do not support the proposition for which they are cited. This pattern suggests that Plaintiff’s attorney, Ms.
However, the pattern indicates that Plaintiff’s counsel may have presented AI-generated citations to the Court. “A citation to one non-existent case may be a mere mistake. But here, the fact that all three citations are non-existent suggests defendant’s counsel may have used artificial intelligence to draft the motion and failed to confirm the accuracy of the citations.” Strike 3 Holdings, LLC v.
Before considering discipline, the Court will order Plaintiff ’s counsel to explain why sanctions should not issue due to the deficiencies discussed in this Order. Accordingly, IT IS ORDERED that within 10 days from the date of this Order, Plaintiff ’s counsel shall show cause why the Court should not impose sanctions under Rule 11 of the Federal Rules of Civil Procedure for submitting non-existent cases and otherwise deficient case law citations to the Court. This explanation should include submitting copies of the cited cases to the Court and/or otherwise providing accurate and existing authority for the cited propositions.