Pelishek v. City of Sheboygan
E.D. Wisconsin · Sep 18, 2025
- Jurisdiction
- federal
- Court
- E.D. Wisconsin
- Record ID
- pelishek-v-city-of-sheboygan-2025-09-18
- Observed outcome
- The court imposed a $4,500 monetary sanction against counsel, with the law firm of McSweeney, Cynkar, and Kachouroff, PLLC held jointly liable.
- Known monetary consequence
- $4,500
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Civil Rights
- Trial
- Monetary
- AI attribution
- Admitted
- Recorded tool
- Westlaw's Quick Check
- Known monetary consequence
- $4,500
- Procedural posture
- Order on sanctions following a show cause hearing pursuant to Federal Rule of Civil Procedure 11(c).
CourtListener / RECAP
Docket or legal-document mirror. The recorded link is hosted by a legal document repository or mirror.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Counsel used Westlaw's Quick Check.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.