Possible $5K Sanctions for Repeated Mis-Citation in Coomer v. Lindell / My Pillow Election-Related Libel Suit

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AI in Court

Possible $5K Sanctions for Repeated Mis-Citation in Coomer v. Lindell / My Pillow Election-Related Libel Suit

"It appears that the Court’s prior admonitions and sanctions have had little, if any, remedial impact."

Eugene Volokh | 3.25.2026 2:35 PM

I blogged last year about the $6K sanctions imposed earlier in this case for AI hallucinations, as well as about the earlier order identifying the hallucinations and the lawyer's response; here's a follow-up, from today's Order on Post-Trial Motions by Judge Nina Wang (D. Colo.):

Before concluding, the Court must address Frankspeech's brief in response to Plaintiff's Motion to Amend Final Judgment. Troublingly, given the background of this case, Frankspeech's response brief misattributes a district court case to the Tenth Circuit. On the first page of its brief, Frankspeech states that "[t]he 10th Circuit recognized in Capital Solutions, LLC v. Konica Minolta Business Solutions USA, Inc., 695 F.Supp.2d 1149, 1154-56 (10th Cir. 2010), that the jury's determination on this issue is entitled to finality." As the Federal Supplement reporter citation indicates, however, Capital Solutions is not a Tenth Circuit decision. See Cap. Sols., LLC v. Konica Minolta Bus.........

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