Skip to main content
Citation Safe

Was Puerto Rico Soccer League NFP, Corp., et al. on the other side of your case?

Check their next brief before they file — Opposition Check verifies every citation in a filed brief for $49, no signup. Get Opposition Check →

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

Court
D. Puerto Rico
Jurisdiction
USA
Decided
2025-09-23
AI tool
Unidentified
Outcome
Order to pay opposing counsel's fees
Monetary penalty
24492 USD

What was hallucinated

False Quotes: Case Law | Attributed to Kevlik that MR 3.7(a)(3) substantial hardship exemption is interpreted broadly to protect against “unnecessary disruption”; court found no mention of MR 3.7 in Kevlik. || False Quotes: Case Law | Quoted Kevlik for “no clear and convincing MR 1.7 conflict”; court found no such language and noted MR 1.7 was not controlling there. || False Quotes: Case Law | Quoted Culebra Enters. as calling disqualification an “extreme sanction” used only after “careful consideration”; court found no such quotes and that the case was about fee sanctions, not disqualification. || Misrepresented: Case Law | Claimed Culebra Enters. held informed consent cures MR 1.7 conflicts and ethical rules are “flexible” absent systemic harm; court found no such support and noted the case did not address MR 1.7. || Misrepresented: Case Law | Asserted Culebra Enters. deferred disqualification until “actual necessity” of lawyer-witness; court found no such language and that the case allowed pretrial work by a potential witness, not deferral of disqualification. || Misrepresented: Case Law | Claimed Culebra Enters. defers disqualification until necessity to testify is “clearly established”; court found no such support. || Fabricated: Case Law | Fabricated First Circuit citation to Estrada; correct case is a D.P.R. decision. || False Quotes: Case Law | Quoted Estrada that disqualification is “not lightly granted”; court found no such quote (only similar general statements). || False Quotes: Case Law | Attributed to Fiandaca that the First Circuit applies Model Rule 3.7 “narrowly” to avoid “tactical misuse”; court found no mention of MR 3.7 and no such quotes. || False Quotes: Case Law | Quoted Fiandaca to label Defendants’ Rule 1.7 claim “wholly speculative” for lack of evidence; court found no such quote in Fiandaca. || False Quotes: Case Law | Used Fiandaca to assert early disqualification is “unduly punitive” and that delay is preferred; court said the opinion held nearly the opposite and contained no such quote. || Misrepresented: Case Law | Cited Fiandaca to argue disqualification would unduly prejudice Plaintiffs; court noted Fiandaca discussed prejudice to the movant seeking disqualification, not to the party opposing it. || False Quotes: Case Law | Quoted Kevlik as imposing a “high standard” for disqualification; court found no such phrasing. || False Quotes: Case Law | Quoted Kevlik that choice of counsel is a “valued right” balanced with “scrupulous care”; court found no such quotes and observed the case emphasizes preventing unethical conduct over unfettered choice in civil cases. || False Quotes: Case Law | Quoted Kevlik that disqualification is unwarranted without “demonstrable detriment”; court found no such language and explained the substantially related test does not require that showing. || Misrepresented: Case Law | Asserted Kevlik requires a “specific showing” of conflicting interests under MR 1.7, not mere affiliation; court said Kevlik’s substantially related test assumes confidences and requires no such specific showing. || Misrepresented: Case Law | Cited Estrada for rule that disqualification requires “tangible harm,” not “theoretical risks”; court said this contradicts Estrada’s recognition that potential threats can suffice under the substantially related test. || False Quotes: Case Law | Quoted Culebra Enters. that necessity is assessed “in light of available alternatives”; court found no such text. || False Quotes: Case Law | Quoted Culebra Enters. that ethical rules prioritize “practical outcomes” over rigid bans; court found the opinion merely limited MR 3.7 to trial advocacy and did not make such a broad pronouncement. || Misrepresented: Case Law | Used Culebra Enters. to claim MR 3.7 disqualification requires “actual necessity,” not “potential relevance”; court found no support and noted the case did not address disqualification. || Misrepresented: Case Law | Stated Culebra Enters. holds hardship weighs “heavily” against disqualification under MR 3.7; court found no such specific weighting in the opinion. || Misrepresented: Case Law | Argued, citing Culebra Enters., that applying MR 3.7 now is premature; court found no such determination in the opinion. || False Quotes: Case Law | Said Estrada upheld representation absent “actual showing” of divided loyalty; court found no such quote and noted Estrada applied different ethical rules. || Misrepresented: Case Law | Asserted Estrada shows delays in filing disqualification motions signal bad faith and late motions are “viewed skeptically”; court found no such support. || False Quotes: Case Law | Quoted Polyagro Plastics that MR-based disqualification requires a “clear and convincing” violation threatening judicial integrity; court found no such language. || Misrepresented: Case Law | Quoted In re Grand Jury Proceedings to require “actual prejudice” not “mere possibility” for disqualification; court found no such quote and noted a serious potential conflict may suffice. || False Quotes: Case Law | Quoted Fiandaca as requiring “specific instances” of conflict and rejecting “hypothetical scenarios”; court found no such quotes or support. || Misrepresented: Case Law | Claimed First Circuit does not let parties “second-guess” co-parties’ joint counsel choice unless clear abuse; court found the Government was permitted to challenge joint counsel in that case. || Misrepresented: Case Law | Asserted the First Circuit dismisses privilege gamesmanship concerns absent “actual prejudice”; court noted the case allows disqualification for a serious potential conflict. || Misrepresented: Case Law | Quoted that privilege issues are resolved “case-by-case,” not preemptively; court noted only Wheat’s general case-specific evaluation language, not Plaintiffs’ formulation. || Misrepresented: Case Law | Asserted MR 8.4 requires “intentional deceit”; court found no mention of MR 8.4 in the opinion. || Misrepresented: Case Law | Quoted Herrera-Venegas to label § 1654 a “fundamental” right to self-representation and that litigants “may conduct their own cases”; court found no such quotes and a different holding. || False Quotes: Case Law | Placed in quotes Oppenheimer language on Rule 26(b)(1) “casts a wide net” and “bears on … any issue …”; court found the quoted phrasing not in the opinion and emphasized current proportionality limits. || Fabricated: Case Law | Fabricated First Circuit citation to the NECC MDL; correct authority is a D. Mass. 2013 order. || False Quotes: Case Law | Quoted NECC MDL that Rule 26 has a “broad sweep”; court found no such quote (only general statements of liberal discovery). || False Quotes: Case Law | Quoted NECC MDL that defendants’ conduct is “inextricably intertwined” with the antitrust conspiracy; court found no such quote (only general discovery breadth language). || Fabricated: Case Law | Fabricated First Circuit citation to Healey v. Gonzalez; Plaintiffs later claimed they meant Healy v. Spencer. || False Quotes: Case Law | Quoted Healy v. Spencer to claim relevance is construed “generously” and discovery limited only if it has “no possible bearing”; court found neither the quotes nor support in that habeas opinion. || False Quotes: Case Law | Quoted In re Subpoena to Witzel that a Rule 26(c) protective order requires a “particular and specific demonstration of fact” beyond conclusory statements; court found no such quote or discussion of that standard. || Misrepresented: Case Law | Relied on Witzel to argue defendants provided only conclusory assertions about 68 witnesses being unmanageable; court said Witzel concerned a motion to compel and did not support that use. || False Quotes: Case Law | Quoted DM Research that antitrust claims often require “exploration of the conspirators’ minds and actions”; court found no such statement. || Misrepresented: Case Law | Cited DM Research to say antitrust cases often require extensive evidence; court noted the case affirmed dismissal before discovery, so the proposition was unsupported. || Fabricated: Case Law | Fabricated First Circuit citation to Sullivan v. Taglianetti; court could not locate the case. || Misrepresented: Case Law | Cited Gill to warn against “arbitrary numerical limits” on witnesses; court found no supporting language in the opinion, which concerned informant’s privilege. || Misrepresented: Case Law | Mischaracterized Whittingham as a post-discovery ruling; court noted discovery was ongoing. || False Quotes: Case Law | Quoted Public Citizen v. Liggett that a protective order requires “specific facts, not conclusory statements”; court found no such quote. || False Quotes: Case Law | Quoted Public Citizen v. Liggett that a “particularized showing” is required; court found no such language. || False Quotes: Case Law | Quoted Anderson v. Cryovac that discovery should be “as broad as possible”; court found no such quote and noted the current relevance and proportionality limits of Rule 26(b)(1). || Fabricated: Case Law | Fabricated First Circuit citation by naming the wrong party in Gill as “Gulfstream Aerospace Corp.” || Misrepresented: Case Law | Used Gill to argue Swiss Penal Code language in a protective order would confuse and delay discovery contrary to First Circuit efficiency goals; court found no support in the opinion. || Misrepresented: Case Law | Cited In re Grand Jury Subpoena (2001) to say ethical rules focus on actual conflicts, not hypothetical risks; court found the case dealt with privilege and did not support that proposition. || Fabricated: Case Law | Fabricated First Circuit citation to United States v. Gannett Co.; court identified only D.D.C. antitrust cases with different content. || False Quotes: Case Law | Quoted Poliquin that a protective order requires a “specific demonstration of need”; court found no such quote and explained Poliquin concerned post-trial protection standards. || Misrepresented: Case Law | Misstated circuit and substance for In re Grand Jury Subpoena (Fourth Circuit), invoking the Hague Evidence Convention which the case does not mention. || Misrepresented: Case Law | Quoted Aerospatiale that Hague procedures are “permissive” at pages 539–40; court noted that wording does not appear there (similar language exists on other pages).

Details

In the Order, the court stated: "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. Levying appropriate sanctions here promotes deterrence without being overly punitive, as contemplated by Rule 11(c)(4).The Court notes that, rather than showing contrition, the Memorandum in Compliance strikes a defiant and deflective tone. (Docket No. 190). It also contains more of the errors that plagued Plaintiffs’ previous four filings. For example, in the “Legal Standard” section of the memorandum, Plaintiffs cite to two cases for the proposition that sanctions are an “extreme remedy” appropriate for instances of prejudice or bad faith. One case makes no mention of sanctions and neither contain the proffered quote Id. at 3. The 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."Monetary sanction was decided in a subsequent decision dated 23 September 2025, available here.

Sanction teardown · D. Puerto Rico, USA · 2025-09-23

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

What happened

In D. Puerto Rico, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • False Quotes (Case Law)
    Attributed to Kevlik that MR 3.7(a)(3) substantial hardship exemption is interpreted broadly to protect against “unnecessary disruption”; court found no mention of MR 3.7 in Kevlik.
  • False Quotes (Case Law)
    Quoted Kevlik for “no clear and convincing MR 1.7 conflict”; court found no such language and noted MR 1.7 was not controlling there.
  • False Quotes (Case Law)
    Quoted Culebra Enters. as calling disqualification an “extreme sanction” used only after “careful consideration”; court found no such quotes and that the case was about fee sanctions, not disqualification.
  • Misrepresented (Case Law)
    Claimed Culebra Enters. held informed consent cures MR 1.7 conflicts and ethical rules are “flexible” absent systemic harm; court found no such support and noted the case did not address MR 1.7.
  • Misrepresented (Case Law)
    Asserted Culebra Enters. deferred disqualification until “actual necessity” of lawyer-witness; court found no such language and that the case allowed pretrial work by a potential witness, not deferral of disqualification.
  • Misrepresented (Case Law)
    Claimed Culebra Enters. defers disqualification until necessity to testify is “clearly established”; court found no such support.
  • Fabricated (Case Law)
    Fabricated First Circuit citation to Estrada; correct case is a D.P.R. decision.
  • False Quotes (Case Law)
    Quoted Estrada that disqualification is “not lightly granted”; court found no such quote (only similar general statements).
  • False Quotes (Case Law)
    Attributed to Fiandaca that the First Circuit applies Model Rule 3.7 “narrowly” to avoid “tactical misuse”; court found no mention of MR 3.7 and no such quotes.
  • False Quotes (Case Law)
    Quoted Fiandaca to label Defendants’ Rule 1.7 claim “wholly speculative” for lack of evidence; court found no such quote in Fiandaca.
  • False Quotes (Case Law)
    Used Fiandaca to assert early disqualification is “unduly punitive” and that delay is preferred; court said the opinion held nearly the opposite and contained no such quote.
  • Misrepresented (Case Law)
    Cited Fiandaca to argue disqualification would unduly prejudice Plaintiffs; court noted Fiandaca discussed prejudice to the movant seeking disqualification, not to the party opposing it.
  • False Quotes (Case Law)
    Quoted Kevlik as imposing a “high standard” for disqualification; court found no such phrasing.
  • False Quotes (Case Law)
    Quoted Kevlik that choice of counsel is a “valued right” balanced with “scrupulous care”; court found no such quotes and observed the case emphasizes preventing unethical conduct over unfettered choice in civil cases.
  • False Quotes (Case Law)
    Quoted Kevlik that disqualification is unwarranted without “demonstrable detriment”; court found no such language and explained the substantially related test does not require that showing.
  • Misrepresented (Case Law)
    Asserted Kevlik requires a “specific showing” of conflicting interests under MR 1.7, not mere affiliation; court said Kevlik’s substantially related test assumes confidences and requires no such specific showing.
  • Misrepresented (Case Law)
    Cited Estrada for rule that disqualification requires “tangible harm,” not “theoretical risks”; court said this contradicts Estrada’s recognition that potential threats can suffice under the substantially related test.
  • False Quotes (Case Law)
    Quoted Culebra Enters. that necessity is assessed “in light of available alternatives”; court found no such text.
  • False Quotes (Case Law)
    Quoted Culebra Enters. that ethical rules prioritize “practical outcomes” over rigid bans; court found the opinion merely limited MR 3.7 to trial advocacy and did not make such a broad pronouncement.
  • Misrepresented (Case Law)
    Used Culebra Enters. to claim MR 3.7 disqualification requires “actual necessity,” not “potential relevance”; court found no support and noted the case did not address disqualification.
  • Misrepresented (Case Law)
    Stated Culebra Enters. holds hardship weighs “heavily” against disqualification under MR 3.7; court found no such specific weighting in the opinion.
  • Misrepresented (Case Law)
    Argued, citing Culebra Enters., that applying MR 3.7 now is premature; court found no such determination in the opinion.
  • False Quotes (Case Law)
    Said Estrada upheld representation absent “actual showing” of divided loyalty; court found no such quote and noted Estrada applied different ethical rules.
  • Misrepresented (Case Law)
    Asserted Estrada shows delays in filing disqualification motions signal bad faith and late motions are “viewed skeptically”; court found no such support.
  • False Quotes (Case Law)
    Quoted Polyagro Plastics that MR-based disqualification requires a “clear and convincing” violation threatening judicial integrity; court found no such language.
  • Misrepresented (Case Law)
    Quoted In re Grand Jury Proceedings to require “actual prejudice” not “mere possibility” for disqualification; court found no such quote and noted a serious potential conflict may suffice.
  • False Quotes (Case Law)
    Quoted Fiandaca as requiring “specific instances” of conflict and rejecting “hypothetical scenarios”; court found no such quotes or support.
  • Misrepresented (Case Law)
    Claimed First Circuit does not let parties “second-guess” co-parties’ joint counsel choice unless clear abuse; court found the Government was permitted to challenge joint counsel in that case.
  • Misrepresented (Case Law)
    Asserted the First Circuit dismisses privilege gamesmanship concerns absent “actual prejudice”; court noted the case allows disqualification for a serious potential conflict.
  • Misrepresented (Case Law)
    Quoted that privilege issues are resolved “case-by-case,” not preemptively; court noted only Wheat’s general case-specific evaluation language, not Plaintiffs’ formulation.
  • Misrepresented (Case Law)
    Asserted MR 8.4 requires “intentional deceit”; court found no mention of MR 8.4 in the opinion.
  • Misrepresented (Case Law)
    Quoted Herrera-Venegas to label § 1654 a “fundamental” right to self-representation and that litigants “may conduct their own cases”; court found no such quotes and a different holding.
  • False Quotes (Case Law)
    Placed in quotes Oppenheimer language on Rule 26(b)(1) “casts a wide net” and “bears on … any issue …”; court found the quoted phrasing not in the opinion and emphasized current proportionality limits.
  • Fabricated (Case Law)
    Fabricated First Circuit citation to the NECC MDL; correct authority is a D. Mass. 2013 order.
  • False Quotes (Case Law)
    Quoted NECC MDL that Rule 26 has a “broad sweep”; court found no such quote (only general statements of liberal discovery).
  • False Quotes (Case Law)
    Quoted NECC MDL that defendants’ conduct is “inextricably intertwined” with the antitrust conspiracy; court found no such quote (only general discovery breadth language).
  • Fabricated (Case Law)
    Fabricated First Circuit citation to Healey v. Gonzalez; Plaintiffs later claimed they meant Healy v. Spencer.
  • False Quotes (Case Law)
    Quoted Healy v. Spencer to claim relevance is construed “generously” and discovery limited only if it has “no possible bearing”; court found neither the quotes nor support in that habeas opinion.
  • False Quotes (Case Law)
    Quoted In re Subpoena to Witzel that a Rule 26(c) protective order requires a “particular and specific demonstration of fact” beyond conclusory statements; court found no such quote or discussion of that standard.
  • Misrepresented (Case Law)
    Relied on Witzel to argue defendants provided only conclusory assertions about 68 witnesses being unmanageable; court said Witzel concerned a motion to compel and did not support that use.
  • False Quotes (Case Law)
    Quoted DM Research that antitrust claims often require “exploration of the conspirators’ minds and actions”; court found no such statement.
  • Misrepresented (Case Law)
    Cited DM Research to say antitrust cases often require extensive evidence; court noted the case affirmed dismissal before discovery, so the proposition was unsupported.
  • Fabricated (Case Law)
    Fabricated First Circuit citation to Sullivan v. Taglianetti; court could not locate the case.
  • Misrepresented (Case Law)
    Cited Gill to warn against “arbitrary numerical limits” on witnesses; court found no supporting language in the opinion, which concerned informant’s privilege.
  • Misrepresented (Case Law)
    Mischaracterized Whittingham as a post-discovery ruling; court noted discovery was ongoing.
  • False Quotes (Case Law)
    Quoted Public Citizen v. Liggett that a protective order requires “specific facts, not conclusory statements”; court found no such quote.
  • False Quotes (Case Law)
    Quoted Public Citizen v. Liggett that a “particularized showing” is required; court found no such language.
  • False Quotes (Case Law)
    Quoted Anderson v. Cryovac that discovery should be “as broad as possible”; court found no such quote and noted the current relevance and proportionality limits of Rule 26(b)(1).
  • Fabricated (Case Law)
    Fabricated First Circuit citation by naming the wrong party in Gill as “Gulfstream Aerospace Corp.”
  • Misrepresented (Case Law)
    Used Gill to argue Swiss Penal Code language in a protective order would confuse and delay discovery contrary to First Circuit efficiency goals; court found no support in the opinion.
  • Misrepresented (Case Law)
    Cited In re Grand Jury Subpoena (2001) to say ethical rules focus on actual conflicts, not hypothetical risks; court found the case dealt with privilege and did not support that proposition.
  • Fabricated (Case Law)
    Fabricated First Circuit citation to United States v. Gannett Co.; court identified only D.D.C. antitrust cases with different content.
  • False Quotes (Case Law)
    Quoted Poliquin that a protective order requires a “specific demonstration of need”; court found no such quote and explained Poliquin concerned post-trial protection standards.
  • Misrepresented (Case Law)
    Misstated circuit and substance for In re Grand Jury Subpoena (Fourth Circuit), invoking the Hague Evidence Convention which the case does not mention.
  • Misrepresented (Case Law)
    Quoted Aerospatiale that Hague procedures are “permissive” at pages 539–40; court noted that wording does not appear there (similar language exists on other pages).

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Order to pay opposing counsel's fees (monetary penalty: 24492 USD.)

Additional detail

In the Order, the court stated: "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. Levying appropriate sanctions here promotes deterrence without being overly punitive, as contemplated by Rule 11(c)(4).The Court notes that, rather than showing contrition, the Memorandum in Compliance strikes a defiant and deflective tone. (Docket No. 190). It also contains more of the errors that plagued Plaintiffs’ previous four filings. For example, in the “Legal Standard” section of the memorandum, Plaintiffs cite to two cases for the proposition that sanctions are an “extreme remedy” appropriate for instances of prejudice or bad faith. One case makes no mention of sanctions and neither contain the proffered quote Id. at 3. The 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."Monetary sanction was decided in a subsequent decision dated 23 September 2025, available here.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/562/Puerto_Rico_Soccer_League_v._Federacion_USA_10_April_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/562/Puerto_Rico_Soccer_League_v._Federacion_USA_10_April_2025.pdf

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checkerBack to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49Sanctions-motion template