Puerto Rico Soccer League NFP, Corp. v. Federacion Puertorriquena de Futbol
U.S. District Court, District of Puerto Rico · D.P.R.
Verified September 30, 2026
- Citation
- Puerto Rico Soccer League NFP, Corp. v. Federacion Puertorriquena de Futbol, No. 3:23-cv-01203-RAM-MDM (D.P.R. Apr. 10, 2025)
- Decided
- April 10, 2025
Summary
Plaintiffs' counsel, led by pro hac vice attorney Ibrahim Reyes, filed four oppositions in March 2025 that the court found "rife" with fabricated quotations, miscited cases, and at least four cases that did not exist as cited. An appendix to Judge Raul M. Arias-Marxuach's order catalogued 55 defective citations across the filings, including false quotes attributed to Kevlik v. Goldstein for a purportedly broad First Circuit reading of Model Rule 3.7(a)(3)'s "substantial hardship" exemption that the court found unsupported. Plaintiffs denied using generative AI and blamed "human oversight under significant time constraints"; the court held the question immaterial because the filings contained "a litany of inaccurate information" regardless of source.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $24,492.10 in defendants' attorneys' fees and costs for responding to the four defective filings (amount set Sept. 23, 2025, ECF 283)
What sanction did the court impose?
The court ordered plaintiffs' counsel to pay defendants' attorneys' fees incurred in responding to Docket Nos. 174, 175, 176, and 177, with defendants given 21 days to submit an itemized fee application. On September 23, 2025 the court set the award at $24,492.10: $6,732.73 to CONCACAF, $12,401.67 to FIFA, and $5,357.70 to FPF (ECF 283 at 25). The court warned that further conduct of this nature would prompt revocation of Mr. Reyes's pro hac vice status and referral for disciplinary proceedings.
Why does Puerto Rico Soccer League NFP, Corp. v. Federacion Puertorriquena de Futbol matter for law firms using AI?
This case illustrates that courts will sanction sloppy citation practice on its own terms, regardless of whether AI was actually used. Judge Arias-Marxuach’s appendix walks through 55 individual defective citations, a level of fact-checking labor that the fee award is meant to compensate. For managing partners, the operational lesson is that a “we did not use AI” defense provides no shelter when filings contain fabricated quotations and nonexistent cases; the duty to verify quoted text against the underlying opinion is independent of the drafting tool.
Sources
Primary sources
- AI tool: plaintiffs denied using generative AI; the court did not make a finding either way and treated the question as immaterial. The Charlotin tag of 'Unidentified' AI is consistent with the order itself.