Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al.
D. Arizona · Apr 29, 2026
What happened in this matter?
The court struck the plaintiff's motion for failure to comply with local rules and issued a formal warning regarding the inclusion of hallucinated case law. The court explicitly inferred the use of generative AI based on the presence of non-existent citations and reminded the pro se litigant of their duty under Rule 11 to verify the accuracy of all filings.
- Why the court cared
- The court reasoned that the inclusion of non-existent case citations in a filing constitutes a failure to meet the duty of accuracy required by Rule 11, regardless of whether the errors resulted from the use of generative AI or other means.
- Why it matters now
- This case illustrates judicial scrutiny of pro se filings containing AI-generated hallucinations. It reinforces that courts hold pro se litigants to the same Rule 11 verification standards as attorneys, with non-existent citations serving as a trigger for judicial intervention and warnings.
Why this matter is tracked
In a pro se action, the District Court for the District of Arizona struck the plaintiff's Motion for Leave to File a Revised Second Amended Complaint for failure to comply with local rules. The Court identified that the plaintiff's filing contained fabricated case citations, specifically “Ellsworth v. Am. Arbitration Ass'n” and “Aguilar v. ASARCO,” which do not exist in the cited jurisdictions. The Court inferred the use of generative artificial intelligence in the preparation of the filing. While the Court did not impose monetary sanctions, it issued a formal warning to the plaintiff, noting that future filings containing fictitious cases or inaccuracies would subject the plaintiff to Rule 11 sanctions.
This case illustrates judicial scrutiny of pro se filings containing AI-generated hallucinations. It reinforces that courts hold pro se litigants to the same Rule 11 verification standards as attorneys, with non-existent citations serving as a trigger for judicial intervention and warnings.
Record details
What the record establishes about AI use
The court inferred the use of generative artificial intelligence.
The court struck the plaintiff's Motion for Leave to File Revised Second Amended Complaint (Doc. 38) for non-compliance with local rules and issued a warning regarding future filings.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited “Ellsworth v. Am. Arbitration Ass'n, 148 Ariz. 17, 19 (App. 1985),” which the Court found does not exist; the Court identified a likely intended real case as Ellsworth v. Am. Arb. Ass'n, 148 P.3d 983 (Utah 2006) (arbitration issue).
- Fabricated: Case Law | Plaintiff cited “Aguilar v. ASARCO” at 780 F.3d 1101 as a Ninth Circuit case; the Court noted no such Ninth Circuit opinion exists and that 780 F.3d 1101 corresponds to Lary v. Trinity Phys. Fin. & Ins. Services (11th Cir. 2015).
Questions this record answers
- What happened in Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al.?
- The court struck the plaintiff's motion for failure to comply with local rules and issued a formal warning regarding the inclusion of hallucinated case law. The court explicitly inferred the use of generative AI based on the presence of non-existent citations and reminded the pro se litigant of their duty under Rule 11 to verify the accuracy of all filings.
- Why does Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al. matter for legal AI risk?
- This case illustrates judicial scrutiny of pro se filings containing AI-generated hallucinations. It reinforces that courts hold pro se litigants to the same Rule 11 verification standards as attorneys, with non-existent citations serving as a trigger for judicial intervention and warnings.
- What does the public record establish about Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al.?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al. summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.