- Filings ‘rife’ with citation, quotation errors, judge says
- Attorneys must pay defendants’ fees related to flawed motions
Attorneys with Reyes Lawyers PA and Olmo & Rodriguez Matias Law Office PSC were sanctioned by a federal judge over extensive errors in filings that were alleged to have been drafted with the help of artificial intelligence, in a lawsuit over control of professional soccer in Puerto Rico.
The plaintiffs’ lawyers must pay attorneys’ fees incurred by the defendants in relation to four filings that contained “dozens” of “striking” errors, Judge Raúl M. Arias-Marxuach of the US District Court for the District of Puerto Rico wrote in a Thursday opinion.
The firms are representing Puerto Rico Soccer League NFP Corp., the media outlet Futbol Boricua Inc., and a number of individual plaintiffs in a racketeering and antitrust suit against the Fédération Internationale de Football Association; the Confederation of North, Central America and Caribbean Association Football; and others. The plaintiffs accuse the defendants of conspiring to restrain trade with the purpose of maintaining control over soccer’s federative arm in Puerto Rico, Federación Puertorriqueña de Fútbol Inc.
The plaintiffs’ firms were accused by the defendants of using generative AI tools to write several court filings that contained “multiple citation errors.”
Arias-Marxuach previously ordered the plaintiffs to show cause to explain the errors. The judge said Thursday the filings were “rife with citations for content that did not exist in the underlying opinion.” Case citations were also improperly formatted, attributed to the wrong courts, or provided inaccurate party names. Although the court could locate similar citations for some cases, “their contents do not align with Plaintiffs’ representations,” Arias-Marxuach wrote.
The firms claimed the “immaterial” errors were an oversight, and argued there’s no evidence they used AI to write the motions.
But whether AI was used or not is “immaterial, what matters is that the Plaintiffs provided the Court with a litany of inaccurate information in support of their claims,” Arias-Marxuach said. The plaintiffs’ counsel “cannot be said to have behaved with the requisite ‘throughness and preparation’ given their admitted haste in drafting the Motions and dozens of errors that resulted.”
Arias-Marxuach warned the plaintiffs’ counsel that “if further problems of this nature or gravity happen again,” the court will move to revoke Ibrahim Reyes’ pro hac vice status and refer the attorneys for disciplinary proceedings.
Paul, Weiss, Rifkind, Wharton & Garrison LLP; Sidley Austin LLP; and others variously represent the defendants.
The case is P.R. Soccer League NFP Corp. v. Federación Puertorriqueña de Futbol, D.P.R., No. 3:23-cv-01203, 4/10/25.
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