This is the second sanction against Kachouroff in the same case. In July 2025, Wang fined both Kachouroff and DeMaster $3,000 each under Federal Rule 11 after they filed a February 2025 response brief containing approximately 30 defective citations—including nonexistent cases, misquotes, and misrepresentations that appeared to stem from unverified AI use. The underlying defamation lawsuit involves a former Dominion Voting Systems executive who sued Lindell for falsely accusing him of rigging the 2020 election. A Colorado jury found Lindell and his company liable for over $2 million in damages in 2025.
The pattern matters. Kachouroff and DeMaster have submitted flawed documents in other cases and offered contradictory excuses—one attorney claimed a wrong draft was filed while on vacation, a claim later disproven by metadata. Wang cited precedents imposing fines up to $15,000 for fictitious citations but deemed $5,000 sufficient here. As courts increasingly scrutinize AI-assisted legal work, this sanction signals judges will hold attorneys accountable for unverified automation in filings, regardless of the underlying case's prominence.