Pelishek v. City of Sheboygan
U.S. District Court, Eastern District of Wisconsin · E.D. Wis. · Wisconsin bar guidance
Verified April 26, 2026
- Citation
- Pelishek v. City of Sheboygan, No. 23-CV-1048 (WED) (E.D. Wis. Sept. 18, 2025)
- Decided
- September 18, 2025
Summary
Plaintiff's counsel Jennifer DeMaster and Chris Kachouroff filed summary judgment briefs containing pervasive misrepresentations of law and fact, including misquoted cases, a citation to a non-existent case, and proposed findings of fact that did not support the propositions for which they were cited. DeMaster used Westlaw's Quick Check but failed to manually verify citations after Quick Check missed errors. Magistrate Judge William E. Duffin found counsel had engaged in similar conduct in Coomer v. Lindell (D. Colo. 2025) and imposed Rule 11 sanctions.
- AI tool:
- Westlaw Quick Check
- Sanction amount:
- $4,500
What sanction did the court impose?
$4,000 sanction against DeMaster and $500 against Kachouroff, with the law firm McSweeney, Cynkar, and Kachouroff, PLLC jointly liable for Kachouroff's portion. Sanctions payable to the Clerk of Court within 28 days. Court declined to dismiss the action but strongly encouraged DeMaster to take CLE courses in legal writing, research, discovery, case management, summary judgment, and substantive law.
Why does Pelishek v. City of Sheboygan matter for law firms using AI?
Pelishek illustrates that vertical legal AI tools, including Westlaw’s Quick Check, do not eliminate the duty to manually verify citations. The court explicitly noted that DeMaster’s use of Quick Check would have mitigated her conduct were it not for her failure to verify after the tool missed misrepresentations and a fabricated case. For managing partners, the case is also notable for the court’s emphasis that misrepresentations of fact, not just hallucinated case law, can drive Rule 11 sanctions when proposed findings of fact do not support the propositions cited.