In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry
TS Puerto Rico · Apr 21, 2026
- Jurisdiction
- state
- Court
- TS Puerto Rico
- Record ID
- in-re-maria-v-irizarry-centeno-anissa-m-bonilla-irizarry-2026-04-21
- Observed outcome
- The Court issued a formal admonishment to the attorneys and ordered the complaint archived, warning that future ethical breaches could lead to suspension.
- Known monetary consequence
- $1,000
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fabricated Case Law
- Fabricated Legal Quotations
- Failure To Verify AI Generated Research
- Fake Citations
- Fabricated Quotes
- Contract
- AI attribution
- Implied
- Recorded tool
- Generative Artificial Intelligence (unspecified)
- Known monetary consequence
- $1,000
- Procedural posture
- Disciplinary proceeding before the Supreme Court of Puerto Rico resulting in a formal admonishment and the archiving of the complaint.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The Court refers to the use of generative artificial intelligence tools.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.