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Outbyte Driver Updater FREEScan for outdated or missing drivers - takes under a minuteDriver Scan →Outbyte PC Repair FREEClear out junk files and repair common Windows errorsFree Scan →In July 2025, a federal judge sanctioned two lawyers for filing a pretrial brief in Coomer v. Lindell that contained nearly 30 defective legal citations. The court ordered $6,000 in attorney sanctions after finding the lawyers violated Rule 11. The filing was associated with claims of AI-produced citations, but the judge’s ruling focused on the lawyers’ failure to verify their work—not on a finding that every word of the brief was generated by AI. MyPillow itself was not sanctioned, and the jury separately found the company not liable for defamation.
What happened in the MyPillow lawyers’ case?
Eric Coomer, a former Dominion Voting Systems executive, sued Mike Lindell, FrankSpeech LLC, and My Pillow, Inc. over statements alleging that Coomer had participated in efforts to interfere with the 2020 presidential election. Before trial, Coomer filed a motion in limine—a request asking the court to decide what evidence may be presented to the jury. The defendants opposed that motion on February 25, 2025.
In a July 7, 2025 order, U.S. District Judge Nina Y. Wang said the opposition contained “nearly thirty defective citations.” The court described nonexistent cases, inaccurate quotations, misstatements of what decisions held, and errors about which court had issued cited authority. For example, the brief attributed United States v. Hassan to the Tenth Circuit even though the cited case was from the Fourth Circuit. The order also identified nonexistent cases including Perkins v. Federal Fruit & Produce Co., Estate of Martinelli v. City & County of Denver, and United States v. Hoffman. The court’s July 7 order details the defects.
Why did the judge sanction the lawyers?
The lawyers said they had mistakenly filed an earlier draft and that a corrected version was ready. Judge Wang examined the drafts and related records and found that the evidence did not substantiate their account of a corrected version being reviewed before filing. The court also found that the purported corrected version still contained substantive errors.
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The judge concluded that Christopher Kachouroff and Jennifer DeMaster had not acted reasonably in certifying that the brief’s legal arguments were warranted by existing law or a nonfrivolous argument to change it. The court therefore found a violation of Federal Rule of Civil Procedure 11, which governs representations made in court filings.
| Person or firm | Sanction ordered in July 2025 |
|---|---|
| Christopher Kachouroff and McSweeney Cynkar & Kachouroff PLLC | $3,000, jointly and severally |
| Jennifer DeMaster | $3,000, individually |
| Total | $6,000 |
The sanctions were imposed on the lawyers and firm, not on Lindell or the defendant companies. The order discusses AI-produced citation errors in the context of counsel’s earlier representations, but it also considered gross carelessness and disputed explanations. It does not establish that the entire brief was AI-generated.
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Was MyPillow found liable in the defamation case?
No. The sanctions concerned the lawyers’ filing and their Rule 11 certification. They were separate from the jury’s verdict in the underlying defamation case. The jury found Lindell and FrankSpeech liable and awarded Coomer more than $2.3 million in damages against them combined; it found MyPillow not liable. Ars Technica’s report on the verdict and sanctions recounts those outcomes.
What did the court say about AI and legal citations?
The court’s central point was that attorneys remain responsible for the accuracy of authorities they submit, whether or not they use generative AI. In a later order addressing another citation problem, Judge Wang wrote: “Regardless of whether generative artificial intelligence was used or not, the Tenth Circuit has been clear that an attorney has a ‘fundamental duty’ to the Court to confirm that all legal authorities in submissions to the Court are accurately cited, reflect accurate quotations, and stand for the propositions for which they are cited.” The March 25, 2026 order states that duty while discussing renewed citation errors.
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For legal practice, the lesson is verification of the final filing, not simply whether AI was used. A responsible review includes opening and reading each cited decision, checking quotations against the original text, confirming the court and precedential status, and reviewing the exact version submitted to the court. The case does not establish how often AI-generated legal citations are wrong or compare the accuracy of particular AI or legal research tools.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What happened after the 2025 sanctions?
On March 25, 2026, Judge Wang identified another citation problem in a post-trial response brief: it cited a nonexistent case, misattributed a district court decision to the Tenth Circuit, and inaccurately described that decision. The judge ordered the defendants to show cause why FrankSpeech, Kachouroff, and DeMaster should not face a further $5,000 sanction jointly and severally, and why Kachouroff and DeMaster should not be referred to their state disciplinary bodies.
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A show-cause order asks parties to explain why a proposed consequence should not be imposed; it is not itself a final sanction. The Gazette reported on the renewed sanctions proceeding in April 2026, while the court’s March order is the controlling record of what was ordered. The final outcome of that proceeding is not established in the available sources.
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