FIFA has asked a US federal judge to dismiss an antitrust lawsuit brought by the Puerto Rico Soccer League after the league’s lawyers allegedly failed to pay $24,492.10 in court-ordered sanctions arising from legal filings containing dozens of erroneous citations.
The latest application, filed on October 6, adds another dimension to a competition law dispute involving football’s international governing body.
Chief US District Judge Raúl Arias-Marxuach previously sanctioned the plaintiffs’ attorneys after identifying 55 defective legal citations in court submissions that appeared to exhibit characteristics associated with AI-generated legal research.
The lawyers have denied using artificial intelligence to prepare the documents.
FIFA now argues that their failure to comply with the court’s financial sanctions provides grounds for dismissing the underlying lawsuit.
The plaintiffs’ lawyers oppose that request, maintaining that dismissal would unfairly penalise their client for the conduct of its legal representatives.
The dispute raises an increasingly important question for the legal profession: when lawyers submit seriously defective material to a court and subsequently fail to comply with sanctions, how far should the consequences extend to the clients they represent?
Why Is FIFA Seeking to Dismiss the Antitrust Lawsuit?
FIFA’s latest request follows sanctions imposed against attorneys representing the Puerto Rico Soccer League.
In April 2025, Judge Arias-Marxuach determined that deficiencies in the lawyers’ submissions warranted sanctions under Federal Rule of Civil Procedure 11 and the court’s inherent authority to address litigation misconduct.
A subsequent order issued on September 23, 2025, established the financial penalty at $24,492.10, payable to FIFA and other defendants.
The sanctions were imposed because of serious deficiencies in the legal submissions regardless of whether generative AI had actually been used to prepare them.
According to FIFA’s latest filing, the penalty remains unpaid more than a year after the financial award was imposed.
The governing body argues that the failure to satisfy the court’s order warrants dismissal of the litigation.
The request does not depend on FIFA persuading the judge that the underlying antitrust allegations are legally or factually unfounded.
Instead, FIFA is seeking to end the proceedings because of the plaintiffs’ lawyers’ alleged failure to comply with a judicial sanction.
That distinction is central to the dispute.
A dismissal on sanctions-related grounds would not amount to a judicial determination that FIFA had defeated the antitrust allegations on their merits.
What Is the Puerto Rico Soccer League’s Antitrust Case About?
The underlying proceedings were brought by the Puerto Rico Soccer League NFP Corp and other plaintiffs against the Puerto Rican Football Federation, FIFA and the Confederation of North, Central America and Caribbean Association Football (CONCACAF), alongside additional defendants.
The plaintiffs allege that football authorities conspired to restrict tournaments and matches in Puerto Rico, unlawfully limiting competition within the territory’s football sector.
FIFA denies wrongdoing.
The allegations raise questions about the application of US antitrust law to the governance of football.
Sports governing bodies frequently establish rules concerning tournament participation, competition structures, membership and the organisation of matches.
Although such rules can serve legitimate sporting and administrative purposes, they may attract antitrust scrutiny where plaintiffs allege that restrictions improperly suppress competition.
The current sanctions dispute, however, threatens to prevent the underlying competition claims from receiving a substantive determination. Procedural challenges can play a decisive role in competition litigation. In another recent US antitrust dispute, the Supreme Court rejected Nexstar’s attempt to halt DirecTV’s lawsuit, allowing the underlying competition claims to proceed.
Judge Identified 55 Erroneous Legal Citations
The sanctions dispute arose after the court identified extensive problems with legal authorities cited in submissions made on behalf of the plaintiffs.
Judge Arias-Marxuach found 55 erroneous citations that appeared to exhibit characteristics associated with AI-generated legal research.
Generative AI systems can produce convincing references to judicial decisions, statutes and legal commentary that do not exist or do not support the propositions attributed to them. Such errors are frequently described as AI hallucinations.
For lawyers, however, the central issue is not simply whether artificial intelligence was used.
Court submissions must accurately represent the law, and attorneys remain responsible for checking the authorities they present to a judge.
Submitting nonexistent or materially inaccurate cases can mislead the court, waste judicial resources and impose unnecessary costs on opposing parties. Similar concerns have emerged in the UK, where the Crown Prosecution Service admitted that potentially AI-generated false legal citations had reached the High Court during extradition proceedings.
The Puerto Rico court’s sanctions demonstrate the potential consequences of serious citation failures.
However, attorneys José Olmo-Rodríguez and Ibrahim Reyes Gándara have denied using artificial intelligence to prepare the problematic submissions.
The court’s concerns about apparent AI-generated citations should therefore not be treated as an admission by the lawyers that they used the technology.
The established issue is that the court identified defective legal citations and imposed sanctions for deficiencies in the submissions.
Lawyers Argue Dismissal Would Unfairly Punish Their Client
The plaintiffs’ attorneys have urged the court to reject FIFA’s request.
They argue that dismissal would unfairly punish their client for the conduct of its lawyers.
In opposing FIFA’s application, the attorneys emphasised that they had not challenged the sanctions award or its amount and had never stated that they would refuse to pay.
Their position is that non-payment should not automatically result in termination of the underlying antitrust proceedings.
The argument raises a broader issue concerning the relationship between lawyers’ professional responsibilities and their clients’ access to justice.
Courts possess powers to sanction attorneys and parties for litigation misconduct, but dismissal is a particularly severe remedy.
Depending on the applicable procedural rules and circumstances, judges may consider the seriousness of the misconduct, whether non-compliance was deliberate, the prejudice caused to opposing parties and whether lesser sanctions would be effective.
The distinction between misconduct attributable to lawyers and conduct attributable to their clients may therefore become significant when Judge Arias-Marxuach considers FIFA’s application.
Can Unpaid Sanctions Justify Dismissal of a Lawsuit?
Federal courts have several mechanisms for addressing litigation misconduct and failures to comply with judicial orders.
These include monetary sanctions, orders requiring payment of opposing parties’ legal expenses and, in sufficiently serious circumstances, dismissal of claims.
Courts also possess inherent authority to manage proceedings and protect the integrity of the judicial process.
However, dismissal is not an automatic consequence of an unpaid sanctions award.
A dismissal arising from non-compliance with a sanctions order would also be legally distinct from a judgment rejecting the plaintiffs’ antitrust allegations after examining the evidence.
Depending on the terms of any dismissal order, it could nevertheless have serious consequences for the plaintiffs’ ability to pursue those claims.
The court must therefore consider the severity of the alleged non-compliance and whether dismissal is an appropriate response under the applicable procedural standards.
For FIFA, the argument is that judicial orders must be enforceable and that prolonged failure to satisfy a financial sanction cannot simply be ignored.
For the plaintiffs, the question is whether ending their antitrust lawsuit would impose a disproportionate penalty on the client for conduct attributed principally to its attorneys.
What Does the Case Mean for AI in Legal Practice?
The FIFA dispute forms part of a wider pattern of US courts confronting unreliable legal filings associated with generative AI.
Since widely available AI tools entered legal workflows, judges have encountered submissions containing fabricated cases, incorrect quotations and inaccurate citations.
The issue has reinforced a fundamental professional principle: lawyers cannot delegate responsibility for the accuracy of their work to automated systems.
AI-assisted tools can help analyse documents, identify potential authorities and prepare preliminary drafts, but their output requires independent verification.The wider debate over AI in US courts increasingly centres on how legal professionals can benefit from the technology without compromising accuracy, confidentiality or independent judicial judgment.
Federal Rule of Civil Procedure 11 requires lawyers presenting papers to federal courts to certify, among other things, that their legal contentions are warranted by existing law or by a non-frivolous argument for extending, modifying or reversing it.
The rule does not prohibit lawyers from using artificial intelligence.
Instead, responsibility remains with the attorney submitting the document.
That distinction is particularly relevant in the FIFA litigation because the sanctioned lawyers deny using AI.
The wider lesson from the case is therefore not simply that lawyers can be punished for misusing artificial intelligence.
It is that lawyers remain responsible for the accuracy of their court submissions regardless of how those documents were produced.
The dispute also demonstrates how the consequences of defective legal work can potentially extend beyond financial penalties if lawyers subsequently fail to comply with a court’s sanctions order.
What Happens Next in FIFA’s Antitrust Lawsuit?
The case remains before Chief US District Judge Raúl Arias-Marxuach in the US District Court for the District of Puerto Rico.
The judge must now decide whether the plaintiffs’ lawyers’ failure to pay the $24,492.10 sanctions award justifies dismissal of the proceedings.
FIFA maintains that the outstanding penalty provides sufficient grounds to terminate the case.
The plaintiffs’ attorneys argue that such an outcome would unfairly penalise their client and prevent its underlying antitrust allegations from being heard.
No ruling on FIFA’s latest application has yet been reported.
The dispute has implications beyond football governance.
As artificial intelligence becomes increasingly integrated into legal practice, courts are confronting questions about verification, professional responsibility and the appropriate consequences when unreliable material enters the judicial process.
In the FIFA case, however, the immediate issue goes one step further.
The court must determine whether failures connected to sanctioned legal submissions and subsequent non-payment can ultimately cost a client the opportunity to pursue its case.