In the ongoing saga of lawyers who are sanctioned for AI generated hallucination citations in pleadings , FIFA (and other defendants) in an antitrust lawsuit filed by the Puerto Rico Soccer League in Puerto Rico, recently obtained an order from Chief U.S. District Judge Raul M. Arias-Marxuach requiring counsel for the plaintiff defunct league to pay FIFA and the other defendants $24,000 in attorney’s fees and costs “for filing briefs that appeared to contain errors hallucinated by artificial intelligence.” Puerto Rico Soccer League NFP, Corp. v. Federacion Puertoriquena de Futbol, No, 23-1203 (D.P.R. 9.23.25)
The judge noted that the motions filed by the Puerto Rico Soccer League “included at least 55 erroneous citations ‘requiring hours of work on the court’s end to check the accuracy of each citation.’ Plaintiffs’ counsel denied using generative AI, but this assertion was questioned by the judge by “the sheer number of inaccurate or nonexistent citations.” The judge noted that the citations were violations of Rule 11 of the Federal Rules of Civil Procedure and applicable ethical rules.
The ordered sanctions are another reminder to lawyers to check and recheck all cases cited in any pleading filed to comply with Rule 11.