Kim Elizabeth Harwell v. WestCare Nevada, Inc.
D. Nevada · Mar 6, 2026
- Jurisdiction
- federal
- Court
- D. Nevada
- Record ID
- kim-elizabeth-harwell-v-westcare-nevada-inc-2026-03-06
- Observed outcome
- The court issued a warning to the plaintiff regarding the use of AI-generated fake citations and granted leave to amend the complaint.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in D. Nevada, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Tort
- Trial
- Warning
- AI attribution
- Reported
- Recorded tool
- generative AI software
- Known monetary consequence
- Not recorded
- Procedural posture
- Order granting in part defendants' motion to dismiss and granting plaintiff leave to amend complaint.
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 stated the plaintiff appeared to use generative AI software.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.