Coomer v. Lindell

The timeline

• 2022Former Dominion executive Eric Coomer sues Mike Lindell and others for defamation in the District of Colorado. Attorneys Christopher Kachouroff and Jennifer DeMaster appear for the defense.
• Feb 2025The defense files an omnibus response brief that the court will later find contains roughly thirty defective citations, misquotes, misstatements of law, and nonexistent cases.
• Jun 2025A jury returns a $2.3 million verdict for Coomer, as reported.
• 7 Jul 2025Judge Wang's sanctions order (2025 WL 1865282): $3,000 against Kachouroff, jointly and severally with his firm, and $3,000 against DeMaster, payable to the court registry by 4 August 2025.
• Soon afterA federal judge in Wisconsin sanctions the same two attorneys in a different case over similar errors, as reported.
• 25 Mar 2026In a separate order, the court flags another citation, a district-court decision cited as a Tenth Circuit ruling that does not exist in that court, in a post-trial filing, and asks why a further $5,000 should not be imposed, as reported.
• 7 May 2026A further sanction of $5,000 against Kachouroff and his firm, as reported; the court declines to make a bar referral.

What the AI did

As reported, the attorneys acknowledged that a generative-AI tool was used in preparing the brief and said the wrong version had been filed, an uncorrected draft rather than the verified final. Also as reported, the attorneys had run the brief through Westlaw Precision's AI analysis before filing, and it flagged no “obviously bad caselaw.” Tool-checking with a second tool was not verification either.

What the court did, and why

Under Rule 11(c)(1), the July 2025 order:

“The Court hereby SANCTIONS Christopher I. Kachouroff and the law firm of McSweeney Cynkar & Kachouroff PLLC, jointly and severally, in the amount of $3,000 pursuant to Rule 11(c)(1); … [and] SANCTIONS Jennifer T. DeMaster in the amount of $3,000”, order of 7 July 2025 (PDF mirror)

The 2026 order, prompted by yet another nonexistent appellate citation in a post-trial brief, raised the penalty to $5,000, as reported by Colorado Politics, with the court writing that Kachouroff “has already been sanctioned twice for this exact type of error” and “had ample notice of the importance of verifying the technical and substantive accuracy of his citations, particularly if and when AI has played a role in the research and drafting process.”

What it changed

Judge Wang's court now requires a certification about AI use with filings, one of the standing requirements collected on our page for her order. And Coomer stands as the record's repeat-offense marker: the first sanction was priced at $3,000; the second, for the same failure, was not. Courts are keeping score across filings, not just within them.

Sources

• Sanctions order of 7 July 2025 (PDF mirror, Colorado Sun); cited in later opinions as 2025 WL 1865282
• NPR's report on the July 2025 order
• Colorado Politics on the March and May 2026 orders, 2026 details as reported
• Coomer v. Lindell, No. 1:22-cv-01129-NYW (D. Colo.), CourtListener docket

Related

• The full sanctions record
• Judge Wang's AI-certification requirement (D. Colo.)
• People v. Crabill, the Colorado state-discipline counterpart
• Every verified AI standing order

Checked 4 August 2026. Details rest on the linked reporting, which is labeled as reported throughout; amounts are consistent across sources. Information, not legal advice.