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HomeCasesKim Elizabeth Harwell v. WestCare Nevada, Inc.
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Corpus matter record

Kim Elizabeth Harwell v. WestCare Nevada, Inc.

D. Nevada · Mar 6, 2026

NV / federalEditorial impact: lowpro sefake citationstorttrialWarning
Direct answer

What happened in this matter?

The court issued a formal warning to the pro se plaintiff regarding the inclusion of a fabricated case citation in her complaint, which the court attributed to the use of generative AI. The court reminded the parties of their obligations under FRCP 11(b)(2) to verify the accuracy of all cited authorities.

Why the court cared
Fabricated: Case Law | Plaintiff cited a non-existent case 'Estate of Saila v. Circle K Corp.' in support of negligence; court could not find the case and noted the citation numbers corresponded to unrelated cases.
Why it matters now
This record documents a Pro Se Litigant filing issue in D. Nevada, with the listed outcome: Warning.

Why this matter is tracked

In a pro se civil action, the court addressed a motion to dismiss and for a more definite statement. The court identified that the plaintiff included a fabricated case citation, 'Estate of Saila v. Circle K Corp.', in support of a negligence claim. The court determined the citation was generated by AI and warned the parties regarding the duty of reasonable inquiry under FRCP 11(b)(2). The court cautioned that future reliance on AI-generated fake cases could result in sanctions, including monetary penalties or nonmonetary directives. The court granted the defendants' motion in part, dismissed several claims with leave to amend, and ordered the plaintiff to clarify the defendants named in her negligence claim.

Operational lesson

This record documents a Pro Se Litigant filing issue in D. Nevada, with the listed outcome: Warning.

Record details

NevadaSingle-state evidence scope
Explore NVOpen its source-linked jurisdiction page and related matters.
CourtD. Nevada
Jurisdictionfederal
Circuit9th Circuit
DateMar 6, 2026
GE
AI toolgenerative AI software
Party typePro Se Litigant
OutcomeThe court issued a warning to the plaintiff regarding the use of AI-generated fake citations and granted leave to amend the complaint.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

reported

The court stated the plaintiff appeared to use generative AI software.

Procedural posture

Order granting in part defendants' motion to dismiss and granting plaintiff leave to amend complaint.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

1 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Plaintiff cited a non-existent case 'Estate of Saila v. Circle K Corp.' in support of negligence; court could not find the case and noted the citation numbers corresponded to unrelated cases.

Questions this record answers

What happened in Kim Elizabeth Harwell v. WestCare Nevada, Inc.?
The court issued a formal warning to the pro se plaintiff regarding the inclusion of a fabricated case citation in her complaint, which the court attributed to the use of generative AI. The court reminded the parties of their obligations under FRCP 11(b)(2) to verify the accuracy of all cited authorities.
Why does Kim Elizabeth Harwell v. WestCare Nevada, Inc. matter for legal AI risk?
This record documents a Pro Se Litigant filing issue in D. Nevada, with the listed outcome: Warning.
What does the public record establish about Kim Elizabeth Harwell v. WestCare Nevada, Inc.?
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Which source supports this Kim Elizabeth Harwell v. WestCare Nevada, Inc. 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.

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