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Rivera-Carrasquillo v. United States

U.S. District Court, District of Puerto Rico · D.P.R.

Other

Verified April 26, 2026

Citation
Rivera-Carrasquillo v. United States, Nos. 21-1198 (ADC) (HRV), 21-1210 (ADC) (HRV), 21-1297 (ADC) (HRV), 2025 WL 3114334 (D.P.R. Nov. 7, 2025) (Ramos-Vega, M.J.)
Decided
November 7, 2025

Summary

In a consolidated Omnibus Memorandum and Order resolving Section 2255 motions filed by petitioners Luis D. Rivera-Carrasquillo, Edwin Bernard Astacio-Espino, and Ramon Lanza-Vazquez, Magistrate Judge Hector L. Ramos-Vega flagged that counsel for Astacio-Espino had cited authority in a "misleading fashion" in a motion to disclose an anonymous juror's number. In footnote 6, the court identified two specific defects: a mischaracterization of Smith v. Phillips, 455 U.S. 209 (1982), as "insisting" on a rule the opinion does not state, and a "non-existent quote" attributed to United States v. Paniagua-Ramos, 251 F.3d 242, 247-48 (1st Cir. 2001), a case the court noted "has nothing to do with numerical identifiers or juror privacy." The opinion's editor's note preserves the defective citations as part of the official record. The order does not name a generative AI tool, but the pattern, a non-existent quote pinned to a real case along with a fabricated proposition, is the signature of unverified AI-assisted drafting.

AI tool:
Unspecified generative AI (implied)
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

What sanction did the court impose?

No monetary sanction, suspension, or bar referral was imposed in the order. The court denied Astacio-Espino's motion to disclose the juror number (Docket No. 75) and publicly identified the misleading citations in a footnote of a published opinion. The motions for leave to amend and to expand the evidentiary hearing were granted in part and denied in part on independent grounds.

Why does Rivera-Carrasquillo v. United States matter for law firms using AI?

For a managing partner, Rivera-Carrasquillo is a useful counterpoint to the cases that draw four-figure fines: a federal magistrate judge can publicly call out misleading citations and a non-existent quote in a footnote of a published opinion without imposing any monetary penalty, and the resulting reputational record will follow counsel through Westlaw search results indefinitely. The order also illustrates a subtler failure mode than fabricated case names. Both defective citations here pair real reporter cites with propositions the cited opinions do not contain, which is precisely what a quick caption-only check, the kind a lawyer running short on time is most tempted to perform, will fail to catch.

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From the blog

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.

Unverified claims:
  • The court does not expressly attribute the defective citations to use of a generative AI tool. The "AI-assisted" characterization is inferred from the fact pattern (non-existent quote tied to a real reporter cite) and is consistent with, but not confirmed by, the opinion text.
  • A CourtListener docket URL was not located during verification; the Charlotin-hosted S3 PDF, which contains the verbatim Westlaw reprint of the order, is the sole cited source.