Puerto Rico Soccer League NFP, Corp., et al. v. Federación Puertorriqueña de Futbol, et al.

Puerto Rico Soccer League NFP, Corp., et al. v. Federación Puertorriqueña de Futbol, et al., Civil No. 23-1203 (RAM) (D.P.R.), before Judge Raúl M. Arias-Marxuach. Plaintiffs are Puerto Rico Soccer League NFP, Corp., Maria Larracuente, Joseph Marc Seralta-Ives, Jose R. Olmo-Rodriguez (also co-counsel), and Futbol Boricua, Inc., suing the Federación Puertorriqueña de Fútbol, Inc. ("FPF"), Iván Rivera-Gutiérrez, José Martínez, Gabriel Ortiz, and Luis Mozo Cañete (the "FPF Defendants"), the Fédération Internationale de Football Association ("FIFA"), and the Confederation of North, Central America and Caribbean Association Football ("CONCACAF") under the Sherman Act (RICO and commonwealth claims were dismissed September 30, 2024). The sanctions ruling comes in two orders: the Opinion & Order at Docket No. 206, filed April 10, 2025 (37 pp.), which found sanctions warranted and ordered counsel to pay the defendants' fees; and the Opinion and Order at Docket No. 283, filed September 23, 2025 (25 pp.), which fixed the amount at $24,492.10. Primary documents (held in `files/sources/` as `D-177-pr-soccer-league-liability-order-doc206.pdf` and `D-177-pr-soccer-league-amount-order-doc283.pdf`): Doc. 206: https://www.govinfo.gov/content/pkg/USCOURTS-prd-3_23-cv-01203/pdf/USCOURTS-prd-3_23-cv-01203-5.pdf ; Doc. 283: https://www.govinfo.gov/content/pkg/USCOURTS-prd-3_23-cv-01203/pdf/USCOURTS-prd-3_23-cv-01203-9.pdf ; Charlotin database entry (dated September 23, 2025; his held source document is Doc. 206): https://www.damiencharlotin.com/hallucinations/ (source document: https://www.damiencharlotin.com/documents/562/Puerto_Rico_Soccer_League_v._Federacion_USA_10_April_2025.pdf). Provenance: backfill entry drafted October 21, 2026, on main's tasking (this matter was flagged as a library gap in the October 15, 2026 sweep), outside the twice-weekly sweep, after primary-source verification from the two orders on govinfo and reconciliation against the Charlotin database (see (3) below). Caveat carried throughout: the court never found that the attorneys actually used generative AI, the defendants alleged it, the attorneys denied it, and the court sanctioned the citation failures themselves (see (2) and (3)).

Plaintiffs' counsel (José R. Olmo-Rodriguez and Ibrahim Reyes; PRESS-ONLY firm identifications: Reyes Lawyers PA and Olmo & Rodriguez Matias Law Office PSC, per Bloomberg Law) submitted four filings on March 9 and 13, 2025: the Response in Opposition to Defendants' Joint Motion to Disqualify Plaintiffs' Counsel (Docket No. 174), the Response in Opposition to Defendants' Joint Motion for Protective Order Limiting the Scope of Discovery (Docket No. 175), the Response in Opposition to Defendants' Joint Motion for Entry of a Protective and Confidentiality Order and Rule 502(d) Order (Docket No. 176), and a Supplement to that response (Docket No. 177). In their March 17, 2025 replies, the defendants claimed the filings contained multiple citation errors and alleged the plaintiffs had used generative artificial intelligence to write them. The court issued an Order to Show Cause on March 18, 2025, amended the next day (Docket Nos. 181 and 187), stating the filings contained "multiple citations that are incorrect, do not contain the quotes or content cited to, and reference cases that cannot be located and thus presumably do not exist," and directing plaintiffs to show cause why sanctions should not be levied for violations of Model Rules 1.1 and 3.3 and Fed. R. Civ. P. 11(b)(2). Plaintiffs' March 21, 2025 Memorandum in Compliance (Docket No. 190) asserted they did not use artificial intelligence, blamed "human oversight under significant time constraints," and characterized the errors as immaterial and inadvertent, cases misspelled, miscited, or misremembered, none fabricated, arguing there was no evidence of AI use because there were no "systematic fabrications." The April 10, 2025 order rejected that account on the documents: the filings were "rife with citations for content that did not exist in the underlying opinion and quotations allegedly summarizing or restating the case law, rather than the exact text of the opinion," and "[t]he misuse of quotation marks was so prevalent that it was unusual for the Court to find a quotation provided by Plaintiffs within the case it was attributed to." The court "categorically rejects" the "minor paraphrasing" / "minor interpretive variances" defense; in places the cited text "expressly contradicted" the proposition offered; citations were "incorrectly formatted with incorrect reporter numbers, attributed to the wrong circuits or districts, or provided incorrect party names." Named examples from the order: Sullivan v. Taglianetti, 588 F.2d 1355, 1357 (1st Cir. 1978), which "[t]he Court could not locate"; United States v. Gannett Co., 835 F.2d 392, 395 (1st Cir. 1987), where the only similar citations are District of Columbia antitrust cases "their contents do not align with Plaintiffs' representations"; and Healey v. Gonzalez, 747 F.3d 111, 121 (1st Cir. 2014), where the case plaintiffs later said they meant "has nothing to do with the propositions Plaintiffs cite it in support of." An appendix to the April order itemizes the erroneous citations filing by filing; the September order states the count: "Plaintiffs' motions included at least fifty-five defective citations, requiring hours of work on the Court's end to check the accuracy of each citation." On the AI question the court's own words are the record: in April, "Whether generative artificial intelligence 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"; in September, "Plaintiffs denied using generative artificial intelligence. But the sheer number of inaccurate or nonexistent citations suggests otherwise. And in any event, the violations of Fed. R. Civ. P. 11 and applicable ethical rules occurred regardless of whether they were caused by misuse of generative artificial intelligence or other means." The show-cause response itself made it worse: the April order notes the Memorandum in Compliance "also contains more of the errors that plagued Plaintiffs' previous four filings", in its Legal Standard section, two cases were cited for the proposition that sanctions are an "extreme remedy" appropriate for prejudice or bad faith, of which "[o]ne case makes no mention of sanctions and neither contain the proffered quote."

Rules: the April 10, 2025 order (Docket No. 206) held that plaintiffs' counsel violated Fed. R. Civ. P. 11(b)(2), counsel "cannot plausibly be understood to have made reasonable inquiries to ensure their representations are 'well-grounded in both law and fact'" (quoting Cruz v. Savage, 896 F.2d 626, 630 (1st Cir. 1990)), and Model Rule 1.1, because counsel "cannot be said to have behaved with the requisite 'thoroughness and preparation' given their admitted haste in drafting the Motions and dozens of errors that resulted"; the tight-deadline excuse failed because counsel could have requested an extension and in fact filed well before the court's deadline. On Model Rule 3.3 the court made no violation finding: "[i]f, indeed, Plaintiffs' errors were not made knowingly, they did not violate Model Rule 3.3." Sanctions were imposed "under Rule 11 and the Court's inherent authority" (citing Chambers v. NASCO), calibrated to deterrence under Rule 11(c)(4): "A simple Google search would have shown the problems in some of Plaintiffs' citations. In other instances, a quick search of the opinion Plaintiffs cited to would have revealed problems." The April order directed plaintiffs' counsel to pay the attorneys' fees the defendants incurred in relation to Docket Nos. 174, 175, 176, and 177 (Rule 11(b)(2) sanctions run against counsel, not the party, per Rule 11(c)(5)(A)), with itemized fee applications due in twenty-one days, and warned that "[i]f further problems of this nature or gravity happen again, it will move to revoke Mr. Ibrahim Reyes' pro hac vice status and refer any implicated attorneys for disciplinary proceedings." Plaintiffs moved for reconsideration on April 22, 2025; the court denied it the same day (Docket Nos. 217 and 219). The September 23, 2025 order (Docket No. 283) quantified the award: the defendants had requested $87,973.00 in fees (CONCACAF $20,927.50; FIFA $52,053.00; FPF and the FPF Defendants $14,992.50); the lodestar came to $58,439.68, which the court reduced by sixty percent, weighing that both attorneys work for small firms and describe themselves as solo practitioners, that the errors had received national attention, and that it was "aware of no cases where a sanction approaching sixty thousand dollars for the misuse of artificial intelligence has been applied" (comparators discussed: Wadsworth, $5,000 plus a pro hac vice revocation; Benjamin v. Costco, collecting a $1,500–$15,000 range; Kruse v. Karlen (D-20), $10,000; Lacey v. State Farm (D-45), $31,100 jointly and severally; Noland (D-2), $10,000), against the aggravators that this matter had "significantly more errors than other cases located by the Court" and that counsel "never offered a satisfactory explanation." Final award: $23,375.87 in fees plus $1,116.23 in costs (Sidley Austin's Westlaw research expenses, awarded to CONCACAF because checking falsified citations "plainly" requires a research platform), for a total of $24,492.10, allocated: $12,401.67 to FIFA, $6,732.73 to CONCACAF, and $5,357.70 to FPF, "Plaintiffs' counsel SHALL pay" (the order names Jose R. Olmo-Rodriguez and Ibrahim Reyes); the order states no joint-and-several term and no payment deadline. Follow-up (PRESS-ONLY, no primary document located): Reuters (October 7, 2026) and Law360 (October 7, 2026) report that on October 6, 2026 FIFA moved to dismiss the remaining antitrust claim because the firm has "not paid a single dollar" of the sanction, more than a year on; Law360 (September 23, 2026) reports the attorneys' response that an unpaid sanction is no basis to end the suit; Law Commentary (October 12, 2026) reports that at a September 1, 2026 hearing the judge described counsel's posture as "simply stalling" and ordered plaintiffs to explain why the lawsuit should continue. The October 6, 2026 filing is a party motion not available on CourtListener/RECAP free access or govinfo, and no court ruling on it was located in primary sources as of October 21, 2026, the nonpayment and dismissal-request facts rest on press reports only and are flagged accordingly. Charlotin reconciliation: Charlotin's database does carry this matter (case name "Puerto Rico Soccer League NFP, Corp., et al. v. Federación Puertorriqueña de Futbol, et al.", court "D. Puerto Rico", date September 23, 2025; party "Lawyer"; AI tool "Unidentified"; outcome "Order to pay opposing counsel's fees"; monetary penalty "24492 USD"; no professional sanction recorded), and his itemization reproduces all 55 defective citations from the April order's appendix. His outcome matches the primary record. Discrepancies and limits, primary documents governing: (i) his penalty figure is rounded to whole dollars ($24,492 vs. the order's exact $24,492.10); (ii) his single row merges a two-order ruling, his held source document is the April 10, 2025 liability order (Doc. 206) while his date is the September 23, 2025 quantification order (Doc. 283), a split his own Details field acknowledges ("Monetary sanction was decided in a subsequent decision dated 23 September 2025"); (iii) his fields do not capture the April order's conditional warning (pro hac vice revocation and disciplinary referral on recurrence) or the same-day denial of reconsideration.

R5, Denied or Doubled Down (graded from the two court orders only, per the standing discipline). The orders record: counsel denied using AI and denied that any case was fabricated, attributing everything to "human oversight under significant time constraints" and "minor paraphrasing" / "minor interpretive variances," a characterization the court "categorically rejects"; the show-cause response itself contained further erroneous citations, including in its sanctions-law Legal Standard section; the court found that "rather than showing contrition, the Memorandum in Compliance strikes a defiant and deflective tone" and that "[t]he Court finds it problematic that Plaintiffs responded to a show cause order to address the problem of multiple inaccurate citations by providing a response containing more erroneous citations"; counsel then moved for reconsideration, denied the same day; and in fixing the amount five months later the court recorded that "Plaintiffs' counsel never offered a satisfactory explanation for why their citations in multiple motions were so severely flawed," maintained the AI denial against the court's observation that "the sheer number of inaccurate or nonexistent citations suggests otherwise," and expressly contrasted counsel's posture with "several of the cases cited above, where various attorneys facing sanctions offered an explanation as to how they erred."

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2026-10-21 addendum (gap-fill backfill, on Alex's direction via main): this batch added D-175, D-176, and D-177, the three named library gaps carried in the sweep notes, each verified from primary documents outside the sweep cycle. D-175 (Prososki v. Regan, 321 Neb. 38, No. S-25-295, opinion filed March 20, 2026): brief stricken, appeal dismissed, counsel W. Gregory Lake referred to the Counsel for Discipline; the court did NOT find AI was used ("fictitious, potentially AI-generated"; "regardless of whether AI was used ... our analysis is ultimately the same") and adopted no aggregate error count (its chart itemizes 20 authorities, 4 fictitious cases); the press version carried in the October 8, 2026 sweep notes (indefinite suspension imposed April 15, 2026; 57 of 63 citations defective; 20 fabrications) is NOT supported by the primary record: a temporary suspension "until further notice" pending final discipline was press-reported in April 2026 (WOWT; order not located; date reported as April 15 or 16) after Lake first admitted AI use by affidavit. Response class R5, graded from the opinion. D-176 (Flycatcher Corp. Ltd v. Affable Avenue LLC, S.D.N.Y. No. 24 Civ. 9429 (KPF)): February 5, 2026 order (Doc. 227) struck the client's brief and entered default judgment against the client for counsel Steven A. Feldman's conduct (14 of 60 cited cases fake; Rule 11 violated "repeatedly and brazenly"; subjective bad faith); October 9, 2026 order (Doc. 364) awarded $38,877.59 against Feldman personally ($37,881.00 fees after a 10% ability-to-pay reduction, plus $996.59 costs). Response class R5. D-177 (Puerto Rico Soccer League v. Federación Puertorriqueña de Futbol, D.P.R. Civil No. 23-1203 (RAM)): two-order Rule 11 ruling, liability April 10, 2025 (Doc. 206), amount September 23, 2025 (Doc. 283): $24,492.10 against plaintiffs' counsel Olmo-Rodriguez and Reyes ($12,401.67 FIFA / $6,732.73 CONCACAF / $5,357.70 FPF) over at least 55 defective citations; the court made NO finding AI was used and no Model Rule 3.3 violation, sanctioning the citation failures themselves; the October 2026 nonpayment/dismissal-motion follow-up is press-reported only and flagged as such in the entry. Response class R5. Cross-Case Preventive Checklist item 19 added from D-176. Nothing from these entries has been published to the public tracker; tracker publication awaits Alex's word via main.

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Every layer of the standard discipline failed on four filings made inside five days. Pull and read every cited authority before filing: the errors here were not exotic, a First Circuit citation the court "could not locate," cases attributed to the wrong circuit, wrong reporter numbers, wrong party names, and the court spelled out the floor: "[a] simple Google search would have shown the problems in some of Plaintiffs' citations." Quotation marks are a representation that the words exist in the opinion; the defining failure was fabricated and misattributed quotations, including quotations from real cases for propositions the cases contradicted, paraphrase without quotation marks if the exact text has not been checked character-for-character. Volume is its own warning sign: fifty-five defective citations across four oppositions is what unverified drafting looks like at scale, and "admitted haste" was the stated cause, the court noted counsel filed well before the deadline and could simply have requested an extension. The response compounded the filing error, and that is the second lesson: a show-cause response is a verification exercise, not a fresh advocacy opportunity. Counsel's memorandum denied everything, minimized the errors as "minor interpretive variances," and contained new erroneous citations in the very section arguing sanctions law, converting a correctable verification failure into findings of defiance (see (6)). A candid explanation of how the errors happened, with corrected citations, is what the court later contrasted favorably in other cases. Finally, the tool question was never a safe harbor: counsel litigated whether AI was used while the court sanctioned the inaccuracy itself, expressly "regardless of whether they were caused by misuse of generative artificial intelligence or other means", whoever or whatever drafted the text, the signing attorneys owned every citation in it.

• govinfo.gov: https://www.govinfo.gov/content/pkg/USCOURTS-prd-3_23-cv-01203/pdf/USCOURTS-prd-3_23-cv-01203-5.pdf
• govinfo.gov: https://www.govinfo.gov/content/pkg/USCOURTS-prd-3_23-cv-01203/pdf/USCOURTS-prd-3_23-cv-01203-9.pdf
• damiencharlotin.com: https://www.damiencharlotin.com/hallucinations/
• damiencharlotin.com: https://www.damiencharlotin.com/documents/562/Puerto_Rico_Soccer_League_v._Federacion_USA_10_April_2025.pdf