Fernando Betancourt Gómez v. Colegio de Profesionales de la Enfermería de Puerto Rico
The case
Fernando Betancourt Gómez v. Colegio de Profesionales de la Enfermería de Puerto Rico, Puerto Rico Court of First Instance, Superior Court of San Juan, August 22, 2025, No. SJ2023CV10615. Judge Larissa N. Ortiz Modestti. Copy of primary document: ~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-80-betancourt-v-colegio-enfermeria.pdf
What happened
Attorneys María V. Irizarry Centeno and Anissa Michelle Bonilla Irizarry, counsel for co-defendant Tomás Alvarado Colón, filed a dismissal motion containing at least six fictitious case references and direct quotations not found in Puerto Rico Supreme Court jurisprudence. The lawyers did not expressly admit using AI, attributing the errors to case selection and invoking the challenges of internet and AI research applications; the court discussed generative-AI risks at length and treated the errors as unreviewed technology-generated citations.
The rule and the sanction
The court imposed a total sanction of $1,000 on the two lawyers under Puerto Rico Rule of Civil Procedure 9.3 for causing unjustified delays, referred both lawyers to the Puerto Rico Supreme Court for disciplinary evaluation of their professional conduct, recused itself from the case and any other matter involving them, and ordered the case reassigned. On the referral, the Supreme Court of Puerto Rico later held (In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry, 2026 TSPR 41, No. AB-2025-0232 (Apr. 21, 2026)) that both lawyers violated Canons 18, 35, and 38 and Rule 9.1, formally admonished them, and archived the complaint after crediting their post-referral mitigation. Caveat: the court made no express finding that AI was used; the AI nexus rests on the lawyers' invocation of AI tools and the court's treatment of the errors as technology-generated.
How it could have been avoided
Verify each cited opinion against the official reporter before filing, especially quotations attributed to a supreme court. Do not rely on internet or AI research applications as the final check on citations.