In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry
TS Puerto Rico · Apr 21, 2026
What happened in this matter?
The Supreme Court of Puerto Rico issued a formal admonishment to two attorneys for submitting filings containing fabricated case law and nonexistent quotes generated by AI. The Court ruled that reliance on AI tools without independent verification violates the duty of professional competence and diligence, warning that future occurrences could result in severe disciplinary sanctions, including suspension.
- Why the court cared
- The Court reasoned that the attorneys failed their duty of technological competence by submitting unverified AI-generated citations. It determined that while the conduct was sanctionable as an abuse of the adversarial system, a formal admonishment was appropriate to balance accountability with the need for professional deterrence in the context of emerging technology.
- Why it matters now
- This decision establishes a clear standard for technological competence in Puerto Rico, mandating that attorneys perform independent human verification of all AI-generated research. It serves as a precedent for how courts may balance disciplinary accountability with the need for guidance as AI becomes integrated into legal practice.
Why this matter is tracked
The Supreme Court of Puerto Rico addressed professional misconduct by attorneys María V. Irizarry Centeno and Anissa M. Bonilla Irizarry, who submitted a motion containing multiple fabricated case citations and nonexistent legal quotes generated by artificial intelligence. The Court emphasized that attorneys have a non-delegable duty of technological competence and must independently verify all AI-generated content. While the Court found the conduct violated ethical canons regarding diligence and competence, it opted to issue a formal admonishment rather than more severe disciplinary measures, noting the attorneys' contrition and the evolving nature of AI-related practice. The Court established a framework for evaluating future AI-related misconduct, focusing on verification, candor, and institutional supervision.
This decision establishes a clear standard for technological competence in Puerto Rico, mandating that attorneys perform independent human verification of all AI-generated research. It serves as a precedent for how courts may balance disciplinary accountability with the need for guidance as AI becomes integrated into legal practice.
Record details
Explore PROpen its source-linked jurisdiction page and related matters.What the record establishes about AI use
The Court refers to the use of generative artificial intelligence tools.
Disciplinary proceeding before the Supreme Court of Puerto Rico resulting in a formal admonishment and the archiving of the complaint.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
6 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Promovidas attributed an ad verbatim quote to 'Suárez v. CMI Caribe, 180 DPR 367, 376 (2010)' that the Court found did not exist or was incorrectly attributed.
- Fabricated: Case Law | Promovidas cited 'Otero-Burgos v. Inter Med. Supplies, Inc., 137 DPR 841, 848 (1995)' and attributed a direct quote which the record shows was nonexistent or misattributed.
- Fabricated: Case Law | Promovidas cited 'Pérez v. Horizon Lines, 2020 TSPR 61' with an asserted quotation about Ley 100 that the Court determined was incorrectly attributed or nonexistent.
- Fabricated: Case Law | Promovidas attributed to 'Rosado v. ELA, 2004 TSPR 13' a textual statement on Ley 115 that the Court found was not supported by the cited decision.
- Fabricated: Case Law | Promovidas cited 'Colón v. Romero Barceló, 112 DPR 573 (1982)' and ascribed a direct quotation regarding Artículo 1802 which the Court found did not appear as quoted in that decision.
- Fabricated: Case Law | Promovidas cited 'Ramos Lozada v. E.L.A., 174 DPR 650 (2008)' attributing a quote on qualified immunity that the Court determined was incorrectly attributed or nonexistent.
Questions this record answers
- What happened in In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry?
- The Supreme Court of Puerto Rico issued a formal admonishment to two attorneys for submitting filings containing fabricated case law and nonexistent quotes generated by AI. The Court ruled that reliance on AI tools without independent verification violates the duty of professional competence and diligence, warning that future occurrences could result in severe disciplinary sanctions, including suspension.
- Why does In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry matter for legal AI risk?
- This decision establishes a clear standard for technological competence in Puerto Rico, mandating that attorneys perform independent human verification of all AI-generated research. It serves as a precedent for how courts may balance disciplinary accountability with the need for guidance as AI becomes integrated into legal practice.
- What does the public record establish about In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry?
- 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 In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry 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.