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The short version: Lawyers for MyPillow founder Mike Lindell acknowledged using several generative-AI tools while preparing a federal court brief. The filing contained nearly 30 defective citations, including misquoted opinions, misstated legal rules and cases that did not exist. The lawyers were sanctioned $6,000 in 2025. In May 2026, one of them was sanctioned again after the court found another citation-verification failure, bringing his sanctions in the case to $8,000.
The court did not sanction Lindell, MyPillow or FrankSpeech in those proceedings. The issue was not simply that AI had been used; it was that attorneys filed inaccurate legal material without conducting the reasonable review required of lawyers.
Who is the “MyPillow guy”?
Mike Lindell is the founder and chief executive associated with MyPillow. The case at issue grew out of his public claims about the 2020 election and Eric Coomer, a former Dominion Voting Systems executive.
Coomer sued Lindell and related defendants for defamation. The defendants included Michael J. Lindell, FrankSpeech LLC and My Pillow, Inc. The case was Coomer v. Lindell et al., Civil Action No. 22-cv-01129-NYW-SBP, in the U.S. District Court for the District of Colorado, before Judge Nina Y. Wang.
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The AI episode involved written legal filings submitted to the court. It was not a case of an AI system arguing before the judge in real time.
What happened to the court brief?
On February 25, 2025, the defendants filed an opposition to Coomer’s motion in limine. A motion in limine is a pretrial request asking a judge to admit or exclude specific evidence.
The filing addressed evidentiary issues involving, among other things, Coomer’s personal life, alleged substance use, religious beliefs, political views and a motor-vehicle accident. Judge Wang later identified nearly 30 defective citations and related legal inaccuracies in the brief.
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According to the court’s orders, the problems included:
- Misquoting opinions that were cited in the brief.
- Attributing legal principles to decisions that did not contain them.
- Misstating whether authority came from the binding U.S. Court of Appeals for the Tenth Circuit.
- Misattributing decisions to the District of Colorado.
- Citing cases that did not exist.
- Using authorities that did not support the legal propositions for which they were cited.
That is why describing the episode simply as “AI made up cases” is incomplete. Some authorities were reportedly nonexistent, but the court identified a wider breakdown in legal accuracy and citation checking.
Judge Wang’s April 23, 2025 order required counsel to explain the filing and the circumstances surrounding its preparation.
Which AI tools did the lawyers say they used?
Attorney Christopher Kachouroff said he used multiple AI-enabled tools in his practice, including:
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- Westlaw AI
- Google Gemini
- X’s Grok
- Claude
- ChatGPT
- Perplexity
The court record establishes that these tools were among those Kachouroff said he used. It does not establish that each tool independently generated a particular erroneous citation, so it would be misleading to assign every mistake to a named product.
Using several systems also did not create independent verification. AI tools can repeat the same incorrect premise, produce confident but unsupported citations or rely on flawed material supplied in a prompt. The only reliable check for a legal citation is to examine the underlying authority and confirm that it says what the filing claims.
What was the lawyers’ initial explanation?
The defense initially characterized the filed document as an earlier draft that had been submitted accidentally. The errors, counsel suggested, resulted from a human filing mistake.
Judge Wang found that explanation insufficient. Whether the document was an earlier draft, a final draft or a document containing AI-assisted text, counsel still had a duty to ensure that the brief was accurate before filing it.
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Why did the court impose sanctions?
The court imposed sanctions under Federal Rule of Civil Procedure 11. In practical terms, Rule 11 requires lawyers to make a reasonable inquiry before presenting a court filing. Legal content must have adequate support, and attorneys cannot treat the filing process as a place to submit unchecked research.
On July 7, 2025, Judge Wang:
- Sanctioned Kachouroff and his law firm, McSweeney Cynkar & Kachouroff PLLC, jointly and severally, $3,000.
- Sanctioned co-counsel Jennifer DeMaster $3,000 separately.
- Made the original order to show cause absolute.
- Declined to extend the monetary sanctions to Lindell, FrankSpeech or MyPillow.
The first round therefore totaled $6,000 in attorney-related sanctions, although the allocation was $3,000 against Kachouroff and his firm and $3,000 against DeMaster.
The July 7 sanctions order explains the court’s findings, the AI disclosures and the reason the sanctions were not imposed on the clients.
Why wasn’t Lindell sanctioned?
The court said Kachouroff had represented that he did not tell Lindell or the corporate defendants that he had used the various AI tools. On that record, Judge Wang placed the documented responsibility on counsel rather than extending the Rule 11 sanctions to Lindell, MyPillow or FrankSpeech.
That does not mean the court endorsed Lindell’s underlying election-related claims. It also does not mean the clients could never face consequences in another proceeding. It means only that, in this particular sanctions matter, the court did not find a basis to impose these penalties on them.
It is also inaccurate to say that Lindell personally was fined or that MyPillow was sanctioned in the cited orders.
What happened in the underlying defamation case?
The sanctions were separate from the merits of Coomer’s defamation claims. The lawyers’ citation problems did not themselves decide whether the defendants were liable for defamation.
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According to Ars Technica’s report on the trial outcome, a jury found Lindell and FrankSpeech liable and awarded Coomer approximately $1.8655 million against FrankSpeech. That reported verdict should be kept distinct from the Rule 11 sanctions imposed on the attorneys.
The story did not end with the first $6,000
The most important update came in 2026. The initial sanctions were not the final citation-related consequence in the case.
On March 25, 2026, Judge Wang issued a post-trial order that denied Lindell and FrankSpeech’s renewed motion for judgment as a matter of law and began a second show-cause proceeding concerning continued citation-verification problems.
On May 7, 2026, the court concluded that Kachouroff had again filed a materially incorrect citation after the earlier sanctions and show-cause proceedings. The court:
- Discharged the second show-cause order as to Jennifer DeMaster.
- Made it absolute as to Kachouroff.
- Sanctioned Kachouroff and his firm an additional $5,000, jointly and severally.
- Declined to sanction FrankSpeech in that second proceeding.
- Declined to refer Kachouroff to the Virginia State Bar, relying in part on his representation that he had stepped back from active trial-level litigation.
The additional penalty brought Kachouroff’s cumulative sanctions in the case to $8,000. The May 7 order is why a current account of the episode should not end with the original 2025 penalty.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What does this case say about lawyers using AI?
AI assistance is not the same as legal validation
The court did not hold that lawyers are forbidden from using generative AI. Nor did it treat every use of AI as sanctionable. The central failure was submitting inaccurate legal material after inadequate review.
AI can help with brainstorming, organization, drafting and locating potentially relevant material. But a lawyer must still open the cited case, confirm that it exists, check the quotation, verify the court and date, and determine whether the decision actually supports the proposition being made.
“The software did it” is not a Rule 11 defense
A lawyer’s signature represents that the filing has been reviewed and meets the applicable professional standards. Responsibility does not disappear because a sentence or citation came from a language model, an office assistant, a legal-research feature or an earlier draft.
The same principle applies when a filing is submitted accidentally. A mistaken upload may explain how an inaccurate document reached the docket, but it does not replace the reasonable pre-filing review that should have caught the problem.
Multiple AI systems do not equal multiple sources
Running a citation through several chatbots may create the appearance of checking, but it is not the same as consulting primary legal authority. Systems can share training data, repeat one another’s errors or produce plausible-looking citations without reliable support.
A defensible workflow treats AI output as unverified research leads. The final check must be against the official opinion, a reliable legal database or another authoritative primary source.
Repeated errors make the quality-control issue more serious
The 2026 order changed the character of the story. It was no longer only an initial AI-assisted filing that escaped review. The court found a renewed citation-verification failure after the first sanctions proceeding.
That does not establish that the second error was generated by AI, and it should not be described as a second AI-generated brief without evidence. It does show why the court focused on the continuing failure to verify citations rather than on the novelty of the technology.
What actually went wrong?
The simplest accurate explanation is:
- AI tools were used during preparation of a legal brief.
- The brief contained nearly 30 defective citations and related inaccuracies.
- The document was filed with the court.
- Counsel’s initial “wrong draft” explanation did not resolve the duty to review the filing.
- The court imposed Rule 11 sanctions on the attorneys, but not on the clients.
- A later citation failure led to another sanction against Kachouroff and his firm.
The lasting lesson is not that AI is uniquely forbidden in legal work. It is that professional verification remains mandatory when AI is used—and the consequences can become more serious when the same basic failure happens again.
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