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Low reported severity Regulatory Action

Colorado federal court fines two MyPillow defence lawyers $3,000 each over a brief with fabricated citations; lead counsel had admitted running it through AI

In the defamation case Coomer v. Lindell in the US District Court for the District of Colorado, a brief that lawyers for Mike Lindell and MyPillow filed on 25 February 2025 contained nearly thirty defective citations, including citations of cases that do not exist. At a conference on 21 April 2025 lead counsel Christopher Kachouroff told Judge Nina Y. Wang that he had drafted the motion and then 'ran it through AI' and had not personally checked the citations. Counsel later said a wrong draft had been filed by mistake; the court was not persuaded. On 7 July 2025 the court found that he and co-counsel Jennifer DeMaster had violated Rule 11 and fined each $3,000 (Kachouroff jointly with his law firm). The court did not sanction Lindell or his companies.

AI system
Unidentified AI drafting tool
Occurred
25 Feb 2025 to 7 Jul 2025
Reported
23 April 2025
Event location
Unknown
What the AI did
Communicated with the person
Reported harm
Professional HarmFinancial LossLegal Harm
Whose AI use
Their own AI use · Someone else’s AI use
Setting
Justice · Work
Evidence
AI involvement supported · Causal attribution supported · 3 sources, 1 underlying account
5 claims: 4 documented, 1 reported. 2 open questions
People reported harmed
2 people

AI system as recorded: A generative AI tool that lead counsel said the draft brief was run through; the court record does not identify which tool was used for this brief

What Happened

The brief. On 25 February 2025 the defendants in Coomer v. Lindell (Mike Lindell, FrankSpeech and MyPillow) filed an opposition to the plaintiff's motion in limine, signed by Christopher Kachouroff of McSweeney Cynkar & Kachouroff PLLC and by Jennifer DeMaster. At the final pretrial conference on 21 April 2025 the court identified nearly thirty defective citations in it: misquotes, misstatements of law, misattributions and, in the court's words, 'most egregiously, citation of cases that do not exist'.

The AI admission. Asked whether the motion was generated by generative artificial intelligence, Kachouroff answered that he had made an outline and drafted the motion 'and then we ran it through AI', and that he personally did not check the citations. DeMaster's later declaration said Kachouroff had told her he believed some of the citations were likely from AI drafts and wanted them deleted.

The explanation and the order. In their response to the order to show cause, counsel said the filed document was an earlier draft submitted by mistake, and Kachouroff declared that he does not rely on AI to do legal research or find cases. The court found that counsel's own communications did not corroborate a corrected version, that the citations to non-existent cases also appeared in the version counsel called final, and that counsel gave no explanation of how those citations appeared absent the use of generative artificial intelligence or gross carelessness. On 7 July 2025 it held that both lawyers violated Rule 11 and fined each $3,000, describing this as the least severe sanction adequate to deter and punish. It did not extend the sanctions to Lindell or his companies because Kachouroff confirmed he had not told them about his use of AI tools.

Limits. The court record does not identify which AI tool was used for this brief; Kachouroff's declaration lists several tools he uses in his practice. NPR reported that the lawyers did not respond to its request for comment.

Reported harm

According to the court's 7 July 2025 order, two defence lawyers were found to have violated Rule 11 and were each fined $3,000 after filing a brief with nearly thirty defective citations, including non-existent cases, which lead counsel had said was run through AI.

Outcome

Resolved

Order of 7 July 2025 (Doc. 383) made the 23 April 2025 order to show cause absolute and imposed Rule 11 sanctions of $3,000 on Christopher I. Kachouroff and McSweeney Cynkar & Kachouroff PLLC jointly and severally and $3,000 on Jennifer T. DeMaster, payable to the court registry by 4 August 2025. The order to show cause had also raised referral of both lawyers to disciplinary proceedings; the final order imposes fines only.

What remains unknown

  • Which AI tool was used on the brief and which citations it introduced.
  • Whether either lawyer has faced bar disciplinary proceedings over the brief; the final order imposes fines only.

What the evidence supports

AI involvement: supported. The court's 7 July 2025 order quotes lead counsel's answer at the 21 April 2025 conference that after drafting the motion 'we ran it through AI' and that he did not check the citations, and quotes co-counsel's declaration that he believed some of the citations were likely from AI drafts. The filed brief contained citations of cases that do not exist, and the court found counsel gave no explanation of how those citations appeared absent the use of generative artificial intelligence or gross carelessness; it fined both lawyers for the brief. The AI output is thus connected to the sanctioned filing by counsel's own statements in the court record. Counsel later declared that he does not rely on AI to do legal research or find cases, and the court did not identify the tool.

5 claims: 4 documented, 1 reported. What the statuses mean

Documented The defendants' opposition to the plaintiff's motion in limine, filed on 25 February 2025 and signed by Kachouroff and DeMaster, contained nearly thirty defective citations, including misquotes and citations of cases that do not exist.

Causal attribution. Established by the court orders, which record the court's own review of the filed brief.

  • govinfo.gov(opens in new tab) supports · English
    'Defendants filed their Brief in Opposition to Plaintiff'; 'the Court identified nearly thirty defective citations in the Opposition'; 'and most egregiously, citation of cases that do not exist'
  • govinfo.gov(opens in new tab) supports · English
    'and most egregiously, citation of cases that do not exist'
Documented At the final pretrial conference on 21 April 2025, asked whether the motion was generated by generative artificial intelligence, Kachouroff said he had drafted it and then ran it through AI, and that he personally did not check the citations.

Causal attribution. Counsel's statement to the court, quoted from the transcript in the 7 July order; it establishes what counsel said, and the AI's role in the defective citations rests on that statement and the co-counsel declaration.

  • govinfo.gov(opens in new tab) supports · English
    'Was this motion generated by generative'; 'Initially, I did an outline for myself, and I'; 'drafted a motion, and then we ran it through AI'; 'I personally did not check it'
  • govinfo.gov(opens in new tab) supports · English
    'Final Pretrial/Trial Preparation Conference held on April 21, 2025'
Documented Co-counsel's declaration said Kachouroff had told her he believed some of the citations were likely from AI drafts; counsel also said a wrong draft had been filed by mistake and Kachouroff declared he does not rely on AI to do legal research or find cases. The court was not persuaded by the wrong-draft explanation and found no explanation of how the citations appeared absent generative AI or gross carelessness.

Causal attribution. The declarations' content and the court's findings are documented by the order; the order does not itself find which tool produced the citations.

  • govinfo.gov(opens in new tab) supports · English
    'believed some of these citations were likely from AI drafts'; 'I do not rely on AI to do legal research or find cases'; 'the use of generative artificial intelligence or gross carelessness by counsel'; 'Nor is this Court persuaded by counsel'
Documented On 7 July 2025 the court held that Kachouroff and DeMaster violated Rule 11 and sanctioned Kachouroff and his law firm jointly $3,000 and DeMaster $3,000, payable by 4 August 2025, and did not extend the sanctions to Lindell or his companies.

Causal attribution. Established by the operative part of the 7 July order; NPR relays it.

  • govinfo.gov(opens in new tab) supports · English
    'The Court hereby SANCTIONS Christopher I. Kachouroff and the law firm'; 'The Court hereby SANCTIONS Jennifer T. DeMaster in the amount of'; 'this Court does not extend the sanctions to Defendants'; 'no later than August 4, 2025'
  • npr.org(opens in new tab) supports · English
    'A federal judge ordered two attorneys representing MyPillow CEO Mike Lindell in a Colorado defamation case to pay $3,000 each'
Reported NPR reported that Kachouroff and DeMaster did not respond to its request for comment.

Causal attribution. NPR's own report of its request.

Sources

3 sources inspected, from 1 underlying account. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

Read in full in English by the research agent (an AI) on 2026-10-14 (HTTP 200). Order of 7 July 2025 (Doc. 383, 20 pages) read in full; the hearing transcript, the declarations and the draft exhibits it cites were not read separately. Applies to s1.

Read in full in English by the research agent (an AI) on 2026-10-14 (HTTP 200). Order to show cause of 23 April 2025 (Doc. 309) read in full. Applies to s2.

Read in full in English by the research agent (an AI) on 2026-10-14 (HTTP 200). NPR reports the 7 July order and quotes it; it adds that the lawyers did not respond to a request for comment. Applies to s3.

Event countries: Unknown. Affected-person countries: Unknown. Court countries: United States.

The brief was filed in, and the sanctions imposed by, the US District Court for the District of Colorado (both orders). Where the lawyers drafted the brief is not stated, so no event or affected-person country is recorded from the court seat.

Reviewed for publication 2026-10-14: Published because the court's 7 July 2025 order documents that two defence lawyers were fined $3,000 each for a brief with nearly thirty defective citations, including non-existent cases, and quotes lead counsel's statement in court that the draft was run through AI and not checked.

People described

Two defence lawyers in a federal defamation case, fined after filing a brief with fabricated and defective citations; named because they are sanctioned professionals in a public court order.

People reported harmed in this case

2 people

1 AI participant · 1 other person harmed

Two people sanctioned in the 7 July 2025 order: lead counsel, who told the court the draft was run through AI (counted as the AI user), and co-counsel who signed the brief, whose own use of AI is not established (counted as another person harmed). The law firm is an organisation and is not counted; the defendants were not sanctioned.

Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.

Tags

#colorado#federal-court#defamation-case#lawyers#fabricated-citations#rule-11-sanction#generative-ai

Cite this case

Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.

APA

NOPE. (2026). Colorado federal court fines two MyPillow defence lawyers $3,000 each over a brief with fabricated citations; lead counsel had admitted running it through AI. AI incidents. https://nope.net/incidents/2025-colorado-federal-court-fines-mypillow-defence-lawyers-over-brief-with-fabricated-citations-after-ai-admission

BibTeX

@misc{2025_colorado_federal_court_fines_mypillow_defence_lawyers_over_brief_with_fabricated_citations_after_ai_admission,
  title = {Colorado federal court fines two MyPillow defence lawyers \$3,000 each over a brief with fabricated citations; lead counsel had admitted running it through AI},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2025-colorado-federal-court-fines-mypillow-defence-lawyers-over-brief-with-fabricated-citations-after-ai-admission}
}

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