Lawyer Fined $5K for AI-Fueled Mis-Citations in My Pillow Libel Case

2 min readSources: Volokh Conspiracy

A federal judge sanctioned lawyer Christopher I. Kachouroff $5,000 for repeated mis-citations in Coomer v. Lindell.

Why it matters: The penalty signals heightened judicial scrutiny of attorneys' reliance on AI tools and underscores the need for rigorous verification of legal citations in contentious election-related defamation cases. Legal teams will likely reevaluate how they use generative AI and supervise filings to avoid similar penalties.

  • Judge Nina Y. Wang fined Kachouroff $5,000 on May 9, 2026.
  • Nearly 30 defective citations, including misquotes and references to non-existent cases, were found.
  • Kachouroff admitted to using generative AI tools to draft error-laden documents.
  • This follows a $3,000 sanction against Kachouroff and his co-counsel in July 2025 for similar violations.

Attorney Christopher I. Kachouroff was ordered by Judge Nina Y. Wang to pay $5,000 in sanctions for repeatedly mis-citing legal authority during the Coomer v. Lindell litigation, a high-profile defamation suit related to election fraud claims.

  • The court identified almost thirty defective citations in Kachouroff’s legal filings, encompassing misquotes, misrepresentations, and citations to cases that do not exist. Details emerged across several filings between 2025 and 2026.
  • Kachouroff admitted to employing generative artificial intelligence tools to assist in preparing these documents, raising concerns about AI "hallucinations"—errors where AI generates inaccurate or fictional legal content. (read more)
  • This is not Kachouroff’s first penalty in the case. In July 2025, both he and his co-counsel Jennifer T. DeMaster were fined $3,000 each for similar mis-citations linked to apparent AI use. (details here)

In her order, Judge Wang was blunt: "Mr. Kachouroff's statements to the Court in this case do not inspire confidence." The court’s intolerance for erroneous citations reflects broader judicial concern over the emergence of AI in legal workflows and a clear expectation that attorneys rigorously check citations regardless of drafting tools.

This episode highlights that courts are prepared to impose tangible penalties for poor citation practices—even when attributed to new technologies.

By the numbers:

  • $5,000 — amount of Kachouroff's May 2026 sanction
  • 30 — approximate number of defective citations in recent filings
  • $3,000 — previous sanction for each attorney in July 2025