Betancourt Gómez v. Colegio de Profesionales de la Enfermería de Puerto Rico
Tribunal de Primera Instancia, Sala Superior de San Juan (Puerto Rico) · P.R. T.P.I. (San Juan)
Verified April 26, 2026
- Citation
- Betancourt Gómez v. Colegio de Profesionales de la Enfermería de P.R., Civil Núm. SJ2023CV10615 (P.R. T.P.I. San Juan Aug. 22, 2025) (Ortiz Modestti, J.)
- Decided
- August 22, 2025
Summary
Attorneys María V. Irizarry Centeno (RUA 10355) and Anissa Michelle Bonilla Irizarry (RUA 18907), representing co-defendant Tomás Alvarado Colón, filed a motion to dismiss containing at least six fabricated or distorted citations to the Puerto Rico Supreme Court, including a wholly nonexistent decision attributed to Suárez v. CMI Caribe, 180 DPR 367 (2010). Counsel attributed the errors to "limitations of consulting general internet sources" and did not expressly admit using AI, but Judge Larissa N. Ortiz Modestti found the pattern, including a recurring "Ashcroft v. Global" misreading of Ashcroft v. Iqbal, indicative of unreviewed output from technological tools. The court grounded its analysis in Canon 35 of the Puerto Rico Code of Professional Ethics, the newly approved Rule 1.19 on Technological Competence and Diligence, and ABA Formal Opinion 512.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,000
What sanction did the court impose?
Under Rule 9.3 of the Puerto Rico Rules of Civil Procedure, the court imposed a $1,000 monetary sanction on counsel, payable in internal revenue stamps within 30 days, and ordered the Secretary to refer the matter to the Supreme Court of Puerto Rico for disciplinary evaluation of both attorneys. Citing Municipio de Carolina v. CH Properties, 200 DPR 701 (2018), Judge Ortiz Modestti recused herself from this case and any future case involving either attorney, and referred the case to the Civil Coordinating Judge for reassignment to the parallel courtroom.
Why does Betancourt Gómez v. Colegio de Profesionales de la Enfermería de Puerto Rico matter for law firms using AI?
Betancourt is the first publicly documented Puerto Rico trial-court sanction for fabricated citations and is notable for grounding the duty to verify in Rule 1.19 of the newly approved Reglas de Conducta Profesional, which takes effect 1 January 2026 and explicitly treats “presenting documents without validating content generated by technological tools” as a diligence failure. For mainland firms with Puerto Rico practices or co-counsel arrangements, the order signals that the island’s bench is aligning with ABA Formal Opinion 512 and is willing to refer attorneys for disciplinary evaluation, recuse from their future appearances, and award fees even where errors are “corrected” after opposing counsel flags them.
Sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.