Multiphone Latin America Inc. v. Millicom International Cellular S.A.
U.S. District Court, Southern District of Florida · S.D. Fla. · Florida bar guidance
Verified May 5, 2026
- Citation
- Multiphone Latin Am. Inc. v. Millicom Int'l Cellular S.A., No. 25-23249-CIV-ALTONAGA/Reid (S.D. Fla. Aug. 28, 2025)
- Decided
- August 28, 2025
Summary
Plaintiff's attorneys David Allen Alvarez and Robert Twombly of White & Twombly, P.A. filed a Response to a motion to dismiss containing two citations to nonexistent cases (purported "Metropolitan Dade County v. Dyer" and "QBE Ins. Corp. v. Dome Constr. Corp."), fabricated quotations, and citations to real cases that do not discuss the propositions for which they were cited (including Morrison v. Nissan Motor Co., 601 F.2d 139). Chief Judge Cecilia M. Altonaga found counsel "likely used AI to generate the Response and failed to ensure the accuracy of citations and legal arguments before signing and filing it." A Proposed Sur-Reply submitted to address the accusations itself misquoted additional cases.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Counts II-VII dismissed with leave to amend. Both attorneys referred to the Southern District of Florida's Ad Hoc Committee on Attorney Admissions, Peer Review, and Attorney Grievance under Local Rule 6(c), and separately referred to the Florida Bar for investigation. No monetary sanction imposed in this order.
Why does Multiphone Latin America Inc. v. Millicom International Cellular S.A. matter for law firms using AI?
Multiphone illustrates how the problem compounds when attorneys try to defend AI-tainted filings without resetting their verification process: the sur-reply submitted to address the opposing party’s “case law flaws” chart introduced fresh misquotations, and the firm’s explanation, that the Response was “a cumulative effort” producing “miscommunication and misapplication of counsels’ research notes,” did not satisfy the court. For managing partners, the case underscores that a single dual referral (federal district committee plus state bar) can attach to multiple attorneys at the same small firm from one filing.
Sources
Primary 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.