The current fee sanction consideration follows an August 2025 ruling in which the same court already sanctioned Bam for the same conduct. That earlier order revoked her pro hac vice status, struck her brief, and required notification to state bar authorities. The distinction in the current proceeding is the judge's focus on the fabricated quotations specifically, though the pattern of misconduct remains unchanged. The scope and timing of any additional fee award have not been determined.
Attorneys should monitor this case as a bellwether for judicial response to AI-generated errors in litigation. The escalating sanctions signal that courts will not treat repeated AI hallucinations as isolated mistakes, particularly when an attorney has already been sanctioned for similar conduct. Firms relying on AI tools for legal research and citation generation face mounting liability exposure. The case underscores the non-delegable duty to verify all citations and quotations before filing, regardless of the tool used to generate them.