Skip to content

Courts on AI / Fabricated or misquoted citations

Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al.

United States District Court for the District of Arizona · Federal district courts · AZ · · 2026 WL 1162306 · No. CV-25-01823-PHX-DJH · opinion

The District of Arizona on 2026-04-29 struck the defective motion and warned the self-represented plaintiff that future fabricated citations may result in sanctions in Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al. The self-represented plaintiff filed a pleading with two fabricated case citations, including Ellsworth v. Am. Arbitration Ass'n.

Disposition
The court struck the defective motion and warned the self-represented plaintiff that future fabricated citations may result in sanctions.
Recorded conduct
The self-represented plaintiff filed a pleading with two fabricated case citations, including Ellsworth v. Am. Arbitration Ass'n and Ellsworth v. Am. Arb. Ass'n. — outcome: warning; actor: litigant in person
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

38-1 at 17–18); see Lary v. Trinity Phys. Fin. & Ins. Services, 780 F. 3d 1101 (11th Cir. 2015). These hallucinations allow the Court to infer that Plaintiff prepared her filing with the use of generativeartificialintelligence(“AI”). Whiletheuseofsuch a tool is not necessarily problematic, the failure to confirm the accuracy of the filing is. Rule 11 requires either a party or an attorney to sign every pleading, motion, or other paper and provides that this signature constitutes a certificate that thesignerhasreadthedocumentandverifieditsaccuracy. See Fed. R. Civ. P. 11. Thisdutyincludesensuringthatallcitations are accurate as well as any quoted portions or descriptions of the referenced case. Plaintiff's pro se status does not relieve her of this requirement.

Authorities cited in the passage: Lary v. Trinity Phys. Fin. & Ins. Services, 780 F · Fed. R. Civ. P. 11 · Ellsworth v. Am. Arbitration Ass'n, 148 Ariz. 17, 19 (App. 1985), which the Court found does not exist · Ellsworth v. Am. Arb. Ass'n, 148 P.3d 983 (Utah 2006) (arbitration issue) · Aguilar v. ASARCO · Lary v. Trinity Phys. Fin. & Ins. Services

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub