Pelishek v. City of Sheboygan

Chad Pelishek v. City of Sheboygan, No. 23-CV-1048, E.D. Wis., sanctions order filed September 18, 2025 (Document 184). Copy of primary document: `files/sources/D-87-pelishek-v-sheboygan.pdf`.

Attorneys Jennifer DeMaster and Chris Kachouroff filed summary judgment briefs containing pervasive legal and factual misrepresentations. They had first-hand experience in Coomer v. Lindell (D. Colo., July 2025) with the danger of AI hallucinating cases, yet kept using AI in a way that produced fabricated caselaw and filed briefs without verifying all citations. Kachouroff signed and filed amended briefs without independently checking the citations DeMaster had supplied.

The court sanctioned counsel under Federal Rule of Civil Procedure 11. DeMaster was sanctioned $4,000 and Kachouroff $500 (his firm, McSweeney, Cynkar, and Kachouroff, PLLC, is jointly liable for his portion), payable to the Clerk of Court within 28 days. Note: the order expressly treats this as mixed misconduct, with extensive factual misrepresentations alongside the AI-related citation misconduct, so the full amount is not attributable to AI use alone.

After any incident of hallucinated citations, treat every subsequent filing as suspect and verify each authority line by line before filing. A supervising or signing attorney must independently check citations rather than taking another lawyer's word for them. Stop using AI research outputs in filings until a reliable verification workflow is in place.