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FIFA Secures Sanctions Against Opposing Counsel for Unverified Citations and Quotations
- Client News
- April 10, 2025
Paul, Weiss won a victory on behalf of Fédération Internationale de Football Association (FIFA) when the U.S. District Court for the District of Puerto Rico sanctioned opposing counsel for filing four motions containing numerous errors, including citations to and quotations of multiple irrelevant or non-existent cases. In flagging the issue for the court, FIFA noted that it could not find one of the cases cited by the plaintiffs on any platform except ChatGPT.
Determining that the plaintiffs’ errors violated Model Rule of Professional Conduct 1.1 (regarding “competent representation”) and Federal Rule of Civil Procedure 11(b)(2) (concerning counsel conducting a reasonable inquiry), the court wrote that, when parties “present quotations from other cases to the Court, they are indicating that the quoted content actually exists and that the Court can rely on their representations.” The court noted that the plaintiffs’ explanation for the errors showed no contrition even though their motions were “rife with citations for content that did not exist.” Consequently, the court issued sanctions requiring plaintiffs’ counsel to pay the attorneys’ fees incurred by FIFA and other defendants in responding to the plaintiffs’ four motions. Additionally, the court warned that, if there is additional such conduct by the plaintiffs’ counsel, it would “refer any implicated attorneys for disciplinary proceedings.”
The Paul, Weiss team includes litigation partners Christopher Boehning and Tiana Voegelin and counsel Daniel Crane and Michael McGregor.