FIFA Wants Antitrust Lawsuit Dismissed After Lawyers Sanctioned Over Suspected AI-Generated Citations

FIFA is asking a federal judge in Puerto Rico to throw out an antitrust lawsuit after attorneys representing a now-defunct soccer league failed to pay nearly $24,500 in sanctions over court filings containing 55 defective legal citations that raised suspicions of artificial intelligence misuse.

In an October 6, 2026, filing, soccer's international governing body urged Chief U.S. District Judge Raúl Arias-Marxuach to dismiss the Puerto Rico Soccer League's remaining antitrust claim, arguing that its attorneys have failed to comply with a sanctions order issued more than a year ago.

The judge ordered attorneys José Olmo-Rodríguez and Ibrahim Reyes Gándara to pay $24,492.10 on September 23, 2025, after finding dozens of inaccurate or nonexistent legal citations across four filings. The submissions included misidentified cases, faulty quotations and unverifiable references that forced opposing counsel and the court to spend additional time reviewing the arguments.

Arias-Marxuach said the errors bore hallmarks of generative AI, although both lawyers denied using the technology. He found that they violated Rule 11 of the Federal Rules of Civil Procedure by failing to reasonably verify the legal authorities supporting their arguments.

The court ordered the attorneys to reimburse FIFA $12,401.67, the Confederation of North, Central America and Caribbean Association Football (CONCACAF) $6,732.73, and the Puerto Rican soccer federation and associated defendants $5,357.70.

FIFA says it began seeking payment in October 2025 but has yet to receive any money. During a September 1, 2026, hearing, Arias-Marxuach questioned the outstanding sanctions, describing the lawyers' conduct as "simply stalling" and ordering the plaintiffs to explain why their lawsuit should continue.

The attorneys subsequently proposed paying $1,000 per month beginning October 15, an arrangement that would take approximately two years to satisfy the penalties. FIFA and CONCACAF opposed the proposal, arguing that it came only after the court raised the possibility of dismissal.

In a September 22 response, the lawyers argued that the sanctions order established no payment deadline. They cited financial difficulties and a serious injury Reyes suffered in March 2026 that required surgery and rehabilitation, limiting his ability to work.

Olmo-Rodríguez and Reyes urged the court to approve their installment plan, arguing that dismissal would unfairly punish the soccer league over penalties imposed personally on its attorneys. FIFA countered that the lawyers had ample opportunity to seek judicial approval for delayed payments and accused them of prolonging the dispute.

The underlying lawsuit, filed in 2023, accuses FIFA, CONCACAF and Puerto Rican soccer officials of conspiring to restrict professional soccer competitions. The league alleges that the organizations used their authority over tournament approvals to interfere with its operations and suppress competition.

FIFA denies wrongdoing. On September 30, 2024, Arias-Marxuach dismissed several claims, including allegations under the federal Racketeer Influenced and Corrupt Organizations Act. A claim under the Sherman Antitrust Act, which prohibits certain agreements that unlawfully restrict competition, remains pending.

The court has yet to rule on FIFA's October 6 request to dismiss the remaining claim.