Pelishek v. City of Sheboygan
E.D. Wisconsin · Sep 18, 2025
What happened in this matter?
The court imposed monetary sanctions totaling $4,500 against plaintiff's counsel, Jennifer DeMaster and Chris Kachouroff, for filing briefs containing pervasive factual and legal misrepresentations. The court found that counsel failed to manually verify citations generated by Westlaw's Quick Check tool, despite prior knowledge of the risks of AI-generated hallucinations and explicit warnings regarding their professional conduct.
- Why the court cared
- The court reasoned that while inexperience may mitigate misconduct, it does not excuse it. Counsel had a duty to manually verify every citation, especially after prior notice of AI-related risks in other litigation. The court found that signing and filing briefs without comprehensive verification was objectively unreasonable under Rule 11, regardless of whether the errors were intentional or the result of ineffective case management.
- Why it matters now
- Paid tools do not absolve you — Westlaw Quick Check output must still be human-verified against the source before any quoted language leaves the firm.
Why this matter is tracked
Misrepresented: Exhibits & Submissions | Proposed fact said City Attorney Adams denied Pelishek the opportunity to respond to a reporter; the cited email exchange contains no such denial. Outcome: Monetary Sanction. Case involved counsel sanctioned in Coomer v. Lindell. In the OSC Order, the court noted:"The fact that Kachouroff and DeMaster corrected some of their misrepresentations before the court or the defendants identified them would ordinarily mitigate their conduct. But the reality is that Kachouroff and DeMaster acted only after the Colorado District Court in Coomer v. Lindell noted similar misconduct. That so many misrepresentations persist supports the inference that counsel’s conduct was not mere negligence but an intentional effort to mislead the court."In her response to the OSC (available here), Counsel disclosed the Westlaw tools she had used.
Paid tools do not absolve you — Westlaw Quick Check output must still be human-verified against the source before any quoted language leaves the firm.
Record details
What the record establishes about AI use
Counsel used Westlaw's Quick Check.
Order on sanctions following a show cause hearing pursuant to Federal Rule of Civil Procedure 11(c).
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
17 citation, quotation, or authority issues are recorded in the source dataset.
- Misrepresented: Exhibits & Submissions | Proposed fact said City Attorney Adams denied Pelishek the opportunity to respond to a reporter; the cited email exchange contains no such denial.
- Misrepresented: Case Law | Asserted a three-part prior restraint test and cited Milwaukee Police Ass’n v. Jones; the test cannot be found on the cited pages or in the case.
- Misrepresented: Case Law | Portrayed Green v. Brennan as involving employer manufacturing a false narrative and pressuring resignation; Green concerned when a constructive discharge claim accrues.
- False Quotes: Case Law | Quoted Swetlik as saying 'falsified government records affecting taxpayer funds' are matters of public concern; the phrase appears nowhere in the case.
- Fabricated: Case Law | Cited a non-existent case to claim supervisory liability of mayor and city attorney in retaliation.
- False Quotes: Case Law | Altered Howell’s Monell standard by quoting language not in the opinion.
- Misrepresented: Case Law | Stated Whittaker emphasized that public accusations eroding professional standing may justify resignation; Whittaker found no hostile environment.
- Misrepresented: Case Law | Used Patton to support constructive discharge based on fabricated accusations and reputational harm; Patton focused on unwanted sexual contact and obsessive conduct.
Show 9 additional discrepancies
- Misrepresented: Case Law | Claimed Ulrey upheld a jury’s constructive discharge finding based on exclusion and retaliation; Ulrey rejected the constructive discharge claim.
- Misrepresented: Exhibits & Submissions | Attributed the word 'exactly' to Rendall-Araujo’s request that Pelishek repeat what was said; the proposed finding of fact did not state she used 'exactly.'
- Misrepresented: Exhibits & Submissions | Asserted Rendall-Araujo 'stated she was standing up to his racism'; the cited proposed findings do not support this.
- False Quotes: Case Law | Inserted 'any guidelines' where Harman said only 'standards.'
- Misrepresented: Case Law | Claimed AFGE held that chilling of protected speech is actionable; the case concerned sequestration and not the First Amendment.
- Misrepresented: Case Law | Said Boumehdi held ostracism and workload manipulation support hostile environment; the case relied on repeated sexist comments and did not say that.
- Misrepresented: Case Law | Asserted Stutler held 'retaliatory gagging' contributes to hostile environment; Stutler was not a hostile environment case and noted ostracism without material harm is insufficient.
- Misrepresented: Case Law | Claimed Woods recognized that false accusations of racism can create a hostile environment; Woods addressed age/disability/FMLA discrimination and not hostile environment.
- Misrepresented: Exhibits & Submissions | Claimed Wolf defended Pelishek and said he did nothing wrong; none of the four cited PPMF paragraphs support this.
Questions this record answers
- What happened in Pelishek v. City of Sheboygan?
- The court imposed monetary sanctions totaling $4,500 against plaintiff's counsel, Jennifer DeMaster and Chris Kachouroff, for filing briefs containing pervasive factual and legal misrepresentations. The court found that counsel failed to manually verify citations generated by Westlaw's Quick Check tool, despite prior knowledge of the risks of AI-generated hallucinations and explicit warnings regarding their professional conduct.
- Why does Pelishek v. City of Sheboygan matter for legal AI risk?
- Paid tools do not absolve you — Westlaw Quick Check output must still be human-verified against the source before any quoted language leaves the firm.
- What does the public record establish about Pelishek v. City of Sheboygan?
- The record summarizes the outcome described in the linked public source. The recorded link is a secondary or other public source and should be checked against the docket where available. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Pelishek v. City of Sheboygan summary?
- The recorded source is CourtListener / RECAP. It is classified as docket or legal-document mirror; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.