Skip to main content
NOPE
Low reported severity Lawsuit Ongoing

Puerto Rico federal judge sanctions a soccer league's lawyers over 55 defective citations he said bore hallmarks of generative AI; the lawyers deny using AI

In an antitrust lawsuit that the Puerto Rico Soccer League brought against FIFA, CONCACAF and Puerto Rican football officials, Chief U.S. District Judge Raúl Arias-Marxuach found dozens of inaccurate or nonexistent legal citations across four filings by the league's two attorneys. According to Law Commentary, he said the errors bore hallmarks of generative AI and found that the lawyers violated Rule 11 by failing to reasonably verify the authorities they cited. Lawyer Monthly reports that the sanctions were decided in April 2025 and that an order of 23 September 2025 set the penalty at $24,492.10, payable to FIFA and the other defendants. Both lawyers have denied using artificial intelligence. In an October 2026 filing FIFA asked the court to dismiss the league's remaining claim because the sanction had not been paid. The lawyers proposed paying $1,000 a month, cited financial difficulties and an injury one of them suffered in March 2026, and argued that dismissal would punish their client for penalties imposed on them personally. The court had not ruled on the dismissal request when these reports were published.

AI system
Unidentified legal research tool (suspected)
Occurred
Apr 2025
Reported
7 October 2026
Event location
Puerto Rico
What the AI did
Relation unknown
Reported harm
Professional HarmFinancial LossLegal Harm
Whose AI use
AI role unknown
Setting
Work · Justice
Evidence
AI involvement suspected · Causal attribution disputed · 3 sources, 2 underlying accounts
5 claims: 5 reported. 3 open questions
People reported harmed
2 people

AI system as recorded: Generative AI that the judge said the defective citations bore hallmarks of; the lawyers deny using AI and no source names a tool

What Happened

The sanction. Law Commentary reports that the judge ordered the two attorneys to pay $24,492.10 on 23 September 2025 'after finding dozens of inaccurate or nonexistent legal citations across four filings'. It reports that he 'said the errors bore hallmarks of generative AI, although both lawyers denied using the technology', and that he found a Rule 11 violation for failing to reasonably verify the authorities. Lawyer Monthly says the judge determined in April 2025 that the deficiencies warranted sanctions under Rule 11 and the court's inherent authority. PYMNTS, citing Reuters, says the judge concluded that the filings contained 55 erroneous citations that appeared to have been generated with artificial intelligence.

The dismissal request. FIFA filed on 6 October 2026 asking the court to dismiss the league's remaining antitrust claim because the sanction had not been paid. Law Commentary reports that, after a 1 September 2026 hearing at which the judge questioned the unpaid sanction, the lawyers proposed paying $1,000 a month from 15 October. In a 22 September response they cited financial difficulties and an injury one of them suffered in March 2026. They argued that dismissal would unfairly punish the league for penalties imposed on its attorneys.

What is not established. No source says which tool, if any, produced the citations. The lawyers deny using AI, and the judge's sanction rests on the failure to verify the citations. The sanction order itself was not read.

Reported harm

Two attorneys were personally ordered to pay $24,492.10 over defective citations the judge said bore hallmarks of generative AI, and their client's remaining claim now faces a dismissal request over the unpaid sum (court record as reported by Law Commentary and Lawyer Monthly)

Outcome

Unknown

The court ordered the two attorneys to pay $24,492.10 to FIFA, CONCACAF and the Puerto Rican federation and associated defendants (order of 23 September 2025, per Lawyer Monthly and Law Commentary). As of the October 2026 reports the sum was unpaid, the lawyers had proposed paying $1,000 a month, and FIFA's request to dismiss the league's remaining Sherman Act claim was pending.

What remains unknown

  • Whether any AI tool was used to prepare the filings, and which one.
  • The text of the April 2025 and September 2025 sanction orders, which were not read.
  • Whether the court will dismiss the league's remaining claim or accept the instalment plan.

What the evidence supports

AI involvement: suspected. The harm is a court's sanction responding to defective citations that the court attributed to suspected generative AI use. Law Commentary reports that the judge said the errors bore hallmarks of generative AI, and PYMNTS, citing Reuters, reports his conclusion that the 55 erroneous citations appeared to have been generated with AI. Both lawyers deny using AI, no source names a tool, and the sanction itself rests on the failure to verify the citations. Because no AI output is established as reaching the lawyers or the court, the relation is unknown under the consequential-response exemption.

5 claims: 5 reported. What the statuses mean

Reported The judge found dozens of inaccurate or nonexistent legal citations across four filings by the league's attorneys and ordered the two attorneys to pay $24,492.10 on 23 September 2025.

Causal attribution. The court record as reported; the order itself was not read.

  • lawcommentary.com(opens in new tab) supports · English
    The judge ordered attorneys José Olmo-Rodríguez and Ibrahim Reyes Gándara to pay $24,492.10 on September 23, 2025, after finding dozens of inaccurate or nonexistent legal citations across four filings.
  • lawyer-monthly.com(opens in new tab) supports · English
    A subsequent order issued on September 23, 2025, established the financial penalty at $24,492.10, payable to FIFA and other defendants.
Reported The judge said the errors bore hallmarks of generative AI and found a Rule 11 violation for failing to reasonably verify the cited authorities.

Causal attribution. The AI attribution is the judge's assessment; the sanction rests on the failure to verify.

  • lawcommentary.com(opens in new tab) supports · English
    Arias-Marxuach said the errors bore hallmarks of generative AI, although both lawyers denied using the technology. He found that they violated Rule 11 of the Federal Rules of Civil Procedure by failing to reasonably verify the legal authorities supporting their arguments.
  • pymnts.com(opens in new tab) supports · English
    previously concluded that filings by the plaintiffs’ lawyers contained 55 erroneous citations that appeared to have been generated with artificial intelligence, according to Reuters.
Reported Both lawyers have denied using artificial intelligence to prepare the filings.

Causal attribution. Counterevidence to the AI attribution.

Reported The judge decided in April 2025 that the deficiencies warranted sanctions under Rule 11 and the court's inherent authority.

Causal attribution. Procedural history of the sanction as reported; no causal claim about AI.

  • lawyer-monthly.com(opens in new tab) supports · English
    In April 2025, Judge Arias-Marxuach determined that deficiencies in the lawyers' submissions warranted sanctions under Federal Rule of Civil Procedure 11 and the court's inherent authority to address litigation misconduct.
Reported FIFA asked the court in an October 2026 filing to dismiss the league's remaining antitrust claim because the sanction had not been paid; the lawyers proposed paying $1,000 a month and argued that dismissal would punish their client.

Causal attribution. The dismissal request responds to the unpaid sanction; its outcome is pending.

  • lawcommentary.com(opens in new tab) supports · English
    In an October 6, 2026, filing, soccer's international governing body urged Chief U.S. District Judge Raúl Arias-Marxuach to dismiss the Puerto Rico Soccer League's remaining antitrust claim; The attorneys subsequently proposed paying $1,000 per month beginning October 15
  • lawyer-monthly.com(opens in new tab) supports · English
    The plaintiffs' lawyers oppose that request, maintaining that dismissal would unfairly penalise their client for the conduct of its legal representatives.

Sources

3 sources inspected, from 2 underlying accounts. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

Read in English in full; no translation. Applies to s1.

Read in English in full; no translation. PYMNTS attributes its account to Reuters reporting; Reuters itself returned HTTP 401 and was not read. Applies to s2.

Read in English in full; no translation. Its account closely follows the Reuters report relayed by PYMNTS and is grouped with that relay. Applies to s3.

Event countries: Puerto Rico. Affected-person countries: Unknown. Court countries: United States.

The filings were made in, and the sanction imposed by, the U.S. District Court before Chief U.S. District Judge Arias-Marxuach in Puerto Rico (Law Commentary: 'a federal judge in Puerto Rico'). The event is recorded under Puerto Rico's ISO code PR, and the court, a U.S. federal district court, under US. The attorneys' residence is not stated.

Reviewed for publication 2026-10-13: Published as a concrete court sanction on two attorneys for defective citations that the judge said bore hallmarks of generative AI, with the lawyers' denial recorded. The AI involvement is the judge's assessment and is disputed.

People described

Two attorneys who represented the Puerto Rico Soccer League and were personally sanctioned

People reported harmed in this case

2 people

0 AI participants · 2 other people harmed

Two attorneys were ordered to pay the sanction (Law Commentary and Lawyer Monthly name both). They are counted as other people harmed because both deny using AI, so neither is established as a direct AI user. The league is an organisation and is not counted.

Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.

Tags

#legal-citations#court-sanction#rule-11#generative-ai-suspected#consequential-response#puerto-rico

Cite this case

Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.

APA

NOPE. (2026). Puerto Rico federal judge sanctions a soccer league's lawyers over 55 defective citations he said bore hallmarks of generative AI; the lawyers deny using AI. AI incidents. https://nope.net/incidents/2025-puerto-rico-federal-court-sanctions-soccer-league-lawyers-over-citations-judge-said-bore-ai-hallmarks

BibTeX

@misc{2025_puerto_rico_federal_court_sanctions_soccer_league_lawyers_over_citations_judge_said_bore_ai_hallmarks,
  title = {Puerto Rico federal judge sanctions a soccer league's lawyers over 55 defective citations he said bore hallmarks of generative AI; the lawyers deny using AI},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2025-puerto-rico-federal-court-sanctions-soccer-league-lawyers-over-citations-judge-said-bore-ai-hallmarks}
}

Related cases

Low Unidentified AI drafting tool

Paraíba, Brazil: judge fines a lawyer R$32,800 over hidden AI commands in a petition, G1 reports; state bar later suspends two lawyers in such cases

A judge of the 5th Mixed Court of Sousa, Paraíba, found hidden instructions aimed at artificial intelligence tools spread over seven pages of a lawyer's motion for clarification in a public-competition case in June 2026, including an order to ignore impartiality and a note calling it a test of whether the judge used only AI to decide. The judge fined the lawyer two penalties of R$16,400 (R$32,800 in total) for bad-faith litigation and contempt of the court's dignity, and referred the case to the Paraíba bar (OAB-PB) and the state prosecutors, G1 reports. The defence said the commands were not inserted deliberately and blamed an error in exporting a file prepared with AI support. An appeal judge refused to suspend the fines on 30 June, the trial judge kept them on reconsideration, and in July, G1 reports, the OAB-PB preventively suspended two lawyers after opening procedures into two hidden-command cases, one of them the Sousa case.

Medium First Drafts and unidentified legal research tool

Fee suit against the City of Aberdeen (N.D. Miss.): four attorneys on both sides sanctioned after AI tools produced fabricated case citations; trial cancelled and both litigants left without counsel

In a fee dispute between a Louisiana attorney and the City of Aberdeen, Mississippi, briefs filed for both sides in late 2025 cited six cases that do not exist. The attorneys admitted the citations came from unverified AI use: the plaintiff's out-of-state counsel, Kathleen M. Wilson, drafted her filing with an AI drafting program called 'First Drafts', and the City's out-of-state counsel, Kathryn Y. Williams, used an in-house AI legal research tool. Senior Judge Sharion Aycock stayed the case and cancelled the March 2026 trial, then on 8 June 2026 revoked both attorneys' pro hac vice admissions, barred them from the district for two years and fined them $2,500 and $3,500, and disqualified and fined the two local counsel who had signed the filings. Both litigants were left without counsel and given 60 days to find new representation.

Medium ChatGPT

New Mexico Supreme Court fines attorney Stephen Aarons $5,000 and removes him from a murder appeal over ChatGPT-fabricated testimony

Santa Fe defense attorney Stephen Aarons used ChatGPT (OpenAI's o3) on a Rev.com transcript and the record to draft briefing in the murder appeal of Oscar Renee Sandoval; the brief contained fabricated witnesses and testimony (including police officers 'Michelle Amarillo' and 'Sanchez' and invented testimony attributed to real people) and misdescribed real precedents. After a 21 August 2026 show-cause hearing at which Aarons admitted he had not verified the output, the New Mexico Supreme Court's written order of 9 September 2026 held him in direct contempt, fined him $5,000 payable to the State Bar Client Protection Fund within 30 days, removed him from the case, barred him from appearing before the court pending a disciplinary-board referral, struck the filed briefs and reassigned the appeal to the public defender.

Low Unidentified case-analysis tool

Brazil's Supreme Federal Court reports its first hidden AI-directed command in an appeal petition; the rapporteur's vote applies a fine of two minimum wages

On 25 September 2026 Brazil's Supreme Federal Court (STF) announced that it had identified, for the first time, hidden commands in a petition intended to steer the court's artificial-intelligence systems toward a decision favourable to one party. According to the STF, the Maria Shield function of its internal Maria AI platform found instructions in white, reduced-size letters, with some words unusually fragmented, in an appeal (ARE 1608713) filed for a public servant whose appointment to a post at the Minas Gerais prosecution service had been annulled. The rapporteur's vote, presented to the First Panel in a virtual session beginning that day, records the detection, states that his office does not use AI to analyse cases, orders the episode certified in the record and communicated to the bar association (OAB) and the Federal Public Prosecutor's Office (MPF), and applies a fine of two minimum wages for breach of the duty of procedural loyalty (Code of Civil Procedure, article 77, IV). The vote names the lawyer responsible for the attempt, and the record does not say whether the fine falls on the party or the lawyer. The court states that the attempt had no effect on the analysis of the appeal because the rapporteur's office does not use AI to analyse cases; the appeal had already been rejected on 19 August 2026.

If you or someone you know is struggling, free and confidential support is available. Find a helpline near you at Signpost.

Back to all incidents