MyPillow Defense Lawyers in Coomer v. Lindell Reportedly Sanctioned for Filing Court Document Allegedly Containing AI-Generated Legal Citations

In February 2025, lawyers Christopher I. Kachouroff and Jennifer T. DeMaster, representing Mike Lindell, reportedly used generative AI to draft a court brief that contained nearly 30 defective or fabricated citations. The error-filled filing violated federal court rules requiring factual and legal accuracy. The judge fined both lawyers $3,000 each, citing either the improper use of AI or gross carelessness as the cause of the misleading legal content.

Risk classification

• Primary risk domain: 7 AI system safety, failures, & limitations
• Primary risk subdomain: 7.3 Lack of capability or robustness

The AI system failed to perform reliably by hallucinating non-existent court cases and misquoting legal precedents in a critical professional application.

Additional risk subdomains

• 5.1 Overreliance and unsafe use: The attorneys exhibited overreliance by submitting AI-generated legal content to a federal court without conducting independent verification of the citations.
• 3.1 False or misleading information: The AI system generated discrete false information in the form of fabricated legal citations and misquoted case law.

Causal factors

• Entity: AI
• Intent: Unintentional
• Timing: Post-deployment

The incident was caused by the AI system generating hallucinated, non-existent legal citations, which was an unexpected and unintentional outcome of the attorneys using the tool to draft their brief.

EU AI Act risk tier

• Risk tier: 3 Limited Risk

Limited Risk: The generative AI tools used (such as Copilot, Gemini, and Grok) are general-purpose AI systems used for text generation, which fall under transparency obligations for AI-generated content but do not constitute high-risk or unacceptable risk applications under the EU AI Act.

AI system and alleged parties

• AI system: unspecified
• AI purpose: Writing Assistant; Technical Text Generation
• Behaviour type: Assistant
• Alleged developer: Unknown large language model developers
• Alleged deployer: McSweeny Synkar and Kachouroff PLLC, Jennifer T. DeMaster, Christopher I. Kachouroff
• Alleged harmed parties: MyPillow, Mike Lindell, McSweeny Synkar and Kachouroff PLLC, Legal integrity, Judicial integrity, Jennifer T. DeMaster, Epistemic integrity, Christopher I. Kachouroff

Harm severity

Severity ratings are based on this scale.

Highest direct severity in any category: Minor. Severity is scored from Negligible to Catastrophic in each harm category, for harm the reports describe as caused directly or indirectly by the AI system.

• Physical: direct Negligible, indirect Negligible
• Infrastructure: direct Negligible, indirect Negligible
• Property: direct Negligible, indirect Negligible
• Financial: direct Negligible, indirect Negligible
• Environmental: direct Negligible, indirect Negligible
• Malicious content: direct Negligible, indirect Negligible
• Differential treatment: direct Negligible, indirect Negligible
• Civil rights: direct Negligible, indirect Negligible
• Democracy: direct Negligible, indirect Negligible
• Privacy: direct Negligible, indirect Negligible
• Psychological: direct Negligible, indirect Minor
• Epistemic: direct Minor, indirect Minor
• Child sexual exploitation and abuse: direct Negligible, indirect Negligible

Psychological

Reported: The report explicitly describes psychological harm in the form of emotional distress experienced by the attorneys.

Indirectly caused: The two attorneys reported experiencing emotional distress, reputational harm, and significant distractions from trial preparation due to the public scrutiny and court hearings surrounding the AI-generated filing.

Epistemic

Reported: The report explicitly describes epistemic harm in the form of fabricated legal citations and fake case law submitted to a federal court.

Directly caused: The AI system generated nearly 30 defective citations, including completely non-existent cases and misquoted legal precedents, which were submitted as actual legal authority in a federal court brief.

Indirectly caused: The submission of fabricated legal arguments wasted court resources and forced the judge and opposing counsel to spend time verifying non-existent authorities.

People affected

• Occurrences reported: 1
• People reportedly harmed: 2
• People reportedly exposed: 4

Potential causes

Management

• Lack of AI Competency Standards: The firm did not establish clear protocols or training for AI integration.
• Failure of Leadership Oversight: Lead partner failed to supervise co-counsel's verification of the brief.

Technology

• AI Hallucinations: Generative AI fabricated nonexistent legal cases and misquoted real precedents.
• Lack of AI Verification Tools: The AI systems lacked built-in mechanisms to flag hallucinated citations.

Data Inputs

• Unverified AI Drafts: Attorneys inputted drafts into AI without validating the resulting outputs.

Human Factors

• Blind Reliance on AI: Attorneys trusted AI output without conducting independent verification.
• Failure to Fact-Check Citations: Lead counsel failed to personally double-check the AI-generated citations.
• Filing of Wrong Draft: Co-counsel mistakenly uploaded an uncorrected draft instead of a final copy.

Process and Methods

• Deficient Quality Control: The firm lacked a systematic process to verify AI-generated legal briefs.
• Improper Delegation of Duties: Citation checking was delegated without verifying that it was actually done.

Regulatory Environment

• Violation of Federal Rule 11: Lawyers failed to certify that claims were warranted by existing law.
• Lack of Standardized AI Rules: Courts and bar associations lack uniform regulations on AI use in practice.

Information quality

• Classification confidence: High
• Reason for confidence: The reports provide consistent, detailed accounts of the court proceedings, the judge's ruling, the specific errors in the brief, and the admissions of the attorneys regarding their use of AI. Multiple independent news sources corroborate the key facts of the incident.
• Ambiguities identified: There is some minor ambiguity regarding the exact AI model used, as the attorney mentioned using a variety of tools including Microsoft Copilot, Google Gemini, and Grok, but did not specify which one generated the specific fake citations.
• Alternative interpretations: None. The facts of the AI-generated hallucinations and subsequent court sanctions are clear and undisputed.

Attorneys representing Mike Lindell were sanctioned 6,000 dollars for filing a federal court brief containing nearly 30 AI-generated errors and fake citations. This incident represents a professional ethics and verification failure with negligible national security implications.

• Overall national security impact: Negligible
• Scope: Single nation
• Primary target: United States
• Alleged perpetrator: Christopher Kachouroff and Jennifer DeMaster

Threat characteristics

• Imminence: Long-term. The immediate incident is resolved through court sanctions, representing a long-term professional standards and verification challenge rather than an active crisis.
• Autonomy: Human-controlled. The AI was used as a writing assistant, and humans retained final control over whether to submit the document, despite failing to verify its contents.
• Novelty: Established threat. AI-generated legal hallucinations and subsequent court sanctions have occurred in several previous legal cases.

Impact by dimension

• Physical security: Negligible. The incident involves a legal filing error with no impact on physical security, critical infrastructure, or human safety.
• Information security: Negligible. No intelligence compromise, classified data theft, or systematic information warfare operations occurred.
• Sovereignty: Negligible. The incident involved a standard civil court filing error that was easily managed through existing judicial procedures with no threat to state authority.
• Economic security: Negligible. The financial impact was limited to minor court-ordered sanctions of 6,000 dollars, with no threat to strategic industries or economic stability.
• Societal stability: Negligible. There was no threat to societal stability, civil liberties, or population-scale safety.