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AI VORTEXLEGAL AI RISK INTELLIGENCE
CASE BRIEF / REVIEW PACKETAV-CB-03867AUGenerated September 10, 2026Evidence checked Sep 10, 2026
TRACKED PUBLIC MATTER

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
ADVISOR READOUT

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.

Why the decision-maker 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.

RECORDED ISSUES

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.
PRIMARY SOURCE

Damien Charlotin case archive

Publisher document archive. The recorded document is hosted in the upstream publisher archive.

Open underlying source

A recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.

EVIDENCE BOUNDARY

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).

PRACTICAL REVIEW IMPLICATIONS

Controls suggested by the public record

  1. Implement mandatory verification protocols for all legal citations, regardless of the research tool used.
  2. Establish a review process to ensure that AI-generated drafts are cross-referenced against official legal databases.
  3. Monitor pro se filings for patterns of non-existent authority that may indicate reliance on unverified AI output.