Rivera-Carrasquillo v. United States
U.S. District Court, District of Puerto Rico · D.P.R.
Conduct
Here a habeas petitioner's retained counsel quoted a passage that does not exist in a First Circuit case and misdescribed a Supreme Court holding, per footnote 6.
Consequence
No sanction or warning; the court denied the juror-number motion and noted the misleading citations in a footnote.
Lesson
Here the magistrate judge checked the motion's authorities and said counsel had cited caselaw misleadingly "once again."
Verified September 29, 2026
- Citation
- Rivera-Carrasquillo v. United States, Nos. 21-1198 (ADC) (HRV), 21-1210 (ADC) (HRV), 21-1297 (ADC) (HRV), Omnibus Memorandum and Order (D.P.R. Nov. 7, 2025) (Ramos-Vega, Mag. J.), ECF No. 74 (No. 21-1198)
- Decided
- November 7, 2025
Summary
In a consolidated Omnibus Memorandum and Order on the Section 2255 petitions of Luis D. Rivera-Carrasquillo, Edwin Bernard Astacio-Espino, and Ramon Lanza-Vazquez, who were jointly tried and are serving life sentences, Magistrate Judge Héctor L. Ramos-Vega addressed Astacio-Espino's motion for disclosure of the juror number of a juror in the anonymously impaneled jury (Docket No. 75). In footnote 6 he wrote: "Counsel once again resorts to citing caselaw in a misleading fashion." Counsel had cited Smith v. Phillips, 455 U.S. 209 (1982), as "insisting" that a juror-bias inquiry "cannot proceed without identifying the juror at issue," but "[n]owhere in the Smith opinion is there a statement" to that effect. The motion also "contains a non-existent quote from United States v. Paniagua-Ramos, 251 F.3d 242, 247-48 (1st Cir. 2001)," offered for the idea that limited disclosure of numerical identifiers is a narrowly tailored measure, but "Paniagua-Ramos has nothing to do with numerical identifiers or juror privacy." The order does not mention artificial intelligence and does not name the attorney.
- AI tool:
- Unidentified (the order says counsel cited caselaw "in a misleading fashion" and quoted a non-existent passage, but does not mention AI or name a tool)
- Amount or terms:
- None
How did the court address the AI-related conduct?
No sanction and no warning. The court denied the motion at Docket No. 75, concluding it could not confirm or deny a juror's identity without being shown legal authority to do so; the footnote is the order's only response to the citation problems. The order also addressed the petitioners' motions to amend, granting them in part and recommending to the presiding District Judge that some new claims be dismissed as time-barred, and set the scope of the joint evidentiary hearing set for December 15, 2025. The motions at Docket Nos. 56 and 57 (Civil No. 21-1198), 44 (Civil No. 21-1210), and 38 and 42 (Civil No. 21-1297) were granted or allowed in part.
Why does Rivera-Carrasquillo v. United States matter for law firms using AI?
Rivera-Carrasquillo is a footnote, not a sanctions ruling. The magistrate judge had ordered Astacio-Espino’s counsel to file a motion “directing me to any authority that would allow the Court to disclose” a juror’s number in a case where the jury had been anonymously impaneled. Counsel complied, and in footnote 6 the court identified two problems with the authorities cited. Smith v. Phillips was described as “insisting” on a case-specific inquiry that “cannot proceed without identifying the juror at issue”; the court found no such statement in Smith. And a quotation offered from United States v. Paniagua-Ramos, 251 F.3d 242 (1st Cir. 2001), does not exist, the court wrote, and the case “has nothing to do with numerical identifiers or juror privacy.”
The footnote opens with “Counsel once again resorts to citing caselaw in a misleading fashion,” which suggests the court had seen similar problems before, though the order does not say where. The nearest instances in the order are footnotes 4 and 5, which concern Astacio-Espino’s descriptions of the record rather than caselaw: an affidavit he cited for alleged threats against Judge Fusté contains no mention of them, and an investigator’s sworn statement “says nothing about Ms. Díaz admitting that she recognized Astacio-Espino as the defendant she voted to convict.” The court imposed nothing and did not mention artificial intelligence, Rule 11, or a referral. It denied the motion because counsel had not pointed to authority permitting the disclosure and the First Circuit had upheld the anonymous jury.
The tracker’s classification of this matter as an AI case is an inference from the pattern of defects, not a finding in the order. Firms documenting compliance may wish to consider that here the court checked the authorities in a motion it had specifically invited, and recorded what it found in the order resolving it.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Verify that quoted language appears in the cited opinion. Here the court found a quotation attributed to Paniagua-Ramos that the case does not contain.
- Review characterizations of holdings, not just citations. The court found that Smith v. Phillips does not say what counsel said it insisted on.
- Track what a court has already said about a filer's citations. Here footnote 6 says counsel "once again" cited caselaw misleadingly.
Sources
Primary sources
- AI attribution is a Charlotin tracker inference: the order does not mention artificial intelligence; it describes the citations as misleading and one quotation as non-existent.
- The footnote's "once again" suggests an earlier instance of misleading citation by the same counsel; the order does not say which filing it means (footnotes 4 and 5 note record descriptions in Astacio-Espino's filings that the court could not confirm, but do not concern caselaw).
- The order does not name Astacio-Espino's retained counsel.