A federal judge financially sanctioned a lawyer for MyPillow CEO Mike Lindell for a second time on Thursday for including a “materially incorrect citation” in a case filing.

U.S. District Court Judge Nina Y. Wang imposed a $5,000 fine on attorney Christopher Kachouroff and his law firm. Because Lindell, his media company, and Kachouroff’s co-counsel were not responsible for the violation, Wang did not penalize them.

“As the Court has emphasized, Mr. Kachouroff has already been sanctioned twice for this exact type of error,” she wrote in a May 7 order. “He 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.”

Last year, a jury in Colorado awarded plaintiff Eric Coomer $2.3 million in damages against Kachouroff’s clients, which included Lindell and his media platform FrankSpeech. Jurors found the defendants defamed Coomer, a former executive of Denver-based Dominion Voting Systems, by making or disseminating unproven statements of election-rigging and accusing him of treason.

During the litigation, Wang discovered approximately 30 “defective citations,” including misquotations, misrepresentations of law, and cases that did not exist in a filing submitted by Kachouroff and attorney Jennifer T. DeMaster. They alleged that they inadvertently filed an earlier draft of the document, and “human error” was to blame.

In July 2025, Wang ordered Kachouroff and his law firm to pay $3,000, and ordered DeMaster to pay $3,000 as well. She imposed the financial sanctions under the federal rule requiring lawyers to certify that they are presenting non-frivolous claims supported by law.

Shortly afterward, a federal judge in Wisconsin handed down financial sanctions against Kachouroff and DeMaster in a different case involving similar errors.

Then, while addressing a set of post-trial motions this year, Wang identified another problem with the defendants’ arguments. In response to a motion from the plaintiff’s attorneys, the defense cited a decision of the U.S. Court of Appeals for the 10th Circuit in their first paragraph, and repeatedly argued the decision meant that Wang should not unilaterally increase the jury’s damages award.

However, that case did not exist.

“The Court cannot ignore this reoccurring conduct simply because the trial is over,” wrote Wang in a March 25 order.

Wang directed Kachouroff and DeMaster to explain why she should not impose an additional $5,000 penalty for another violation of the rules. Wang also asked the attorneys to address why she should not refer them to the disciplinary bodies in their respective states.

Kachouroff took sole responsibility for the faulty citation. He wrote that the decision was “still a real” case, albeit from the trial courts instead of the appeals court.

The rules do not “contemplate sanctions for every minor or inconsequential citation defect,” Kachouroff argued. He also said the mistake was not “the same type of AI generated error” that arose previously.

“The Response Brief did not contain an improper or unsupported legal principle. This explanation by no means minimizes what the Court rightly perceives concerning imprecise citations,” Kachouroff continued, “but they are not the type of error that supports sanctions.”

In her order, Wang said she had “a significant amount of skepticism” that artificial intelligence played no role in the latest mistake. She also pointed to Kachouroff’s inconsistent statements throughout the case about his use of AI tools.

“The obviousness of the error alone indicates that Mr. Kachouroff failed to reasonably review the Response before filing it,” Wang wrote. “Regardless of whether or not generative AI was used, this is not the type of error a seasoned attorney would or should make.”

She determined that the pattern of conduct justified a more severe financial sanction. Wang cited other judges’ decisions imposing up to $15,000 in penalties for fictitious citations, but she decided $5,000 would be a sufficient deterrent.

Wang further noted she was declining to refer Kachouroff to his state bar for potential discipline.

The case is Coomer v. Lindell et al.