Coomer v. Lindell

What sanction did the court impose?

Judge Wang imposed monetary sanctions of $3,000 against each attorney, $6,000 total, payable personally and not chargeable to the client. The court declined to impose sanctions on Lindell or MyPillow. Judge Wang wrote that the court "derives no joy from sanctioning attorneys who appear before it" but that the duty of candor required the order. Eight months later, on March 25, 2026, Judge Wang issued a second Order to Show Cause against Frankspeech and the same attorneys after a post-trial response brief contained roughly thirty further defective citations, including a 2010 District of Kansas opinion (Capital Solutions, LLC v. Konica Minolta Business Solutions USA, Inc., 695 F. Supp. 2d 1149) misattributed to the Tenth Circuit. The 2026 OSC proposed an additional $5,000 joint-and-several sanction and disciplinary referrals to the Virginia and Wisconsin state bars, with the court observing that "the Court's prior admonitions and sanctions have had little, if any, remedial impact."

Why does Coomer v. Lindell matter for law firms using AI?

Coomer v. Lindell is the high-water mark for AI-tool stacking in a sanctioned filing: counsel acknowledged consulting seven distinct generative AI products in preparing a single opposition brief, yet still produced nearly thirty defective citations including fabricated cases and misquoted holdings. The case is also the rare instance where the same court has sanctioned the same attorneys twice for the same category of error. A $6,000 monetary sanction in July 2025 did not prevent a second filing eight months later containing roughly thirty further defective citations, including a Kansas district court decision dressed up as binding Tenth Circuit authority. For managing partners, the case illustrates two compounding risks: adding more AI tools does not improve verification, and once a firm is on a court’s record for AI-assisted citation failures, judicial patience erodes quickly. The next OSC arrives with bar-referral language attached, and Rule 11 liability attaches to the signing attorney regardless of which tool produced the error.