Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al.
D. Arizona · Apr 29, 2026
- Jurisdiction
- federal
- Court
- D. Arizona
- Record ID
- bathsheba-nichole-adams-v-kiewit-infrastructure-west-company-et-al-2026-04-29
- Observed outcome
- Motion for leave to amend was stricken from the record; the court issued a formal warning regarding future filings.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Fake Citations
- Contract
- Trial
- Warning
- Struck Filing
- AI attribution
- Implied
- Recorded tool
- generative artificial intelligence
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court inferred the use of generative artificial intelligence.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all legal citations, regardless of the research tool used.
- Establish a review process to ensure that AI-generated drafts are cross-referenced against official legal databases.
- Monitor pro se filings for patterns of non-existent authority that may indicate reliance on unverified AI output.