Fernando Betancourt Gómez v. Colegio de Profesionales
Puerto Rico · Aug 22, 2025
What happened in this matter?
The court sanctioned two attorneys $1,000 for filing a motion containing multiple fabricated case citations and quotes. The judge determined the attorneys failed to exercise necessary diligence in verifying AI-generated or internet-sourced legal research, referred them to the Puerto Rico Supreme Court for disciplinary review, and recused herself from all matters involving the counsel.
- Why the court cared
- The court reasoned that while technology is useful, attorneys have an ethical duty under the Code of Professional Ethics to verify the accuracy of all legal research. The court found that the attorneys' failure to check the existence of cited cases and quotes constituted a lack of diligence and candor, causing unjustified delay and wasting judicial resources.
- Why it matters now
- Spanish-language and local-jurisdiction citations require the same verification rigor as federal reporters; assign a shepardizing step.
Why this matter is tracked
The court sanctioned two attorneys for submitting a motion containing six fictitious case citations and fabricated judicial quotes. The attorneys attributed the errors to the use of internet research tools and AI, claiming an involuntary error. The court rejected the defense, noting that the attorneys failed to independently verify the generated content, thereby violating their duty of competence and candor. The court imposed a $1,000 monetary sanction for causing unjustified delay, referred the attorneys to the Puerto Rico Supreme Court for disciplinary evaluation, and recused itself from all cases involving these attorneys, ordering the case reassigned.
Spanish-language and local-jurisdiction citations require the same verification rigor as federal reporters; assign a shepardizing step.
Record details
Explore PROpen its source-linked jurisdiction page and related matters.What the record establishes about AI use
The attorneys referenced internet search engines and AI tools as the source of the errors.
Trial court resolution regarding a motion to dismiss and subsequent motions for sanctions.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
7 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Motion attributed a non-existent Suárez v. CMI Caribe, 180 DPR 367, 376 (2010) and quoted the Tribunal Supremo text — court found the citation and quoted text fictitious.
- Fabricated: Case Law | Motion cited Otero-Burgos v. Inter Med Supplies, Inc., 137 DPR 841, 848 (1995) with an attributed Supreme Court quote that does not exist; court found the citation fictitious.
- Fabricated: Case Law | Motion cited Pérez v. Horizon Lines, 2020 TSPR 61 and attributed a textual quote of the Tribunal Supremo that the court could not locate; found fictitious.
- Fabricated: Case Law | Motion cited Rosado v. ELA, 2004 TSPR 13 and attributed a quotation about Ley 115 that does not appear in the reported decision; court treated the citation as fictitious.
- False Quotes: Case Law | Motion relied on Colón v. Romero Barceló, 112 DPR 573 (1982) (a real decision) but attributed a specific quoted formulation that the court determined does not appear in that opinion.
- Fabricated: Case Law | Motion cited Ramos Lozada v. ELA, 174 DPR 650 (2008) and attributed a quoted formulation on qualified immunity that the court could not find; treated as fictitious.
- Misrepresented: Case Law | Repeated misnaming of a known U.S. Supreme Court case as 'Ashcroft v. Global, 556 US 662 (2009)' instead of Ashcroft v. Iqbal — court noted this as a likely technological-generation or transcription error.
Questions this record answers
- What happened in Fernando Betancourt Gómez v. Colegio de Profesionales?
- The court sanctioned two attorneys $1,000 for filing a motion containing multiple fabricated case citations and quotes. The judge determined the attorneys failed to exercise necessary diligence in verifying AI-generated or internet-sourced legal research, referred them to the Puerto Rico Supreme Court for disciplinary review, and recused herself from all matters involving the counsel.
- Why does Fernando Betancourt Gómez v. Colegio de Profesionales matter for legal AI risk?
- Spanish-language and local-jurisdiction citations require the same verification rigor as federal reporters; assign a shepardizing step.
- What does the public record establish about Fernando Betancourt Gómez v. Colegio de Profesionales?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Fernando Betancourt Gómez v. Colegio de Profesionales summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.