A UK court victory for an AI-only legal service exposes a gap in Puerto Rico’s new ethics rules, which govern attorneys but have no path to license the tech platforms doing the work
In May 2026, a freelance HR consultant in London named Tamires Camal Taquidir recovered £7,000 in unpaid fees after a three-hour trial at Wandsworth County Court. What made the case notable wasn’t the amount, it was who did the work to get her there. Camal Taquidir hired Garfield AI, a UK legal-tech company authorized by the Solicitors Regulation Authority (SRA) as the first purely AI-based firm permitted to provide regulated legal services in England and Wales.
Garfield’s technology handled the pre-action correspondence, the claim, the witness statements, and the trial bundle. A human barrister was retained only at the end, to stand up in court. The claimant’s total legal spend was roughly £400. The defendant, who fielded both a solicitor and a barrister, lost.
It is tempting to read this as a novelty story, a curiosity about robots practicing law. It is closer to a preview of a regulatory question Puerto Rico has not yet had to answer, but will.
Start with what the UK actually built to make this possible. Garfield.Law Ltd is not simply a lawyer using software; it is an entity, the company itself, holding a license from the SRA. That is possible because England and Wales created a category called the Alternative Business Structure (ABS) under the Legal Services Act 2007, which allows the SRA to regulate legal-services businesses, not only the individual solicitors inside them. Before ABS, only lawyer-owned firms could deliver regulated legal services. After it, a technology company built around an AI drafting engine can hold its own license, provided it meets conduct and accountability standards, with a licensed solicitor still answerable for the output.
Puerto Rico has no such category. Our new Rules of Professional Conduct, adopted by the Puerto Rico Supreme Court through Resolution ER-2025-02 on June 17, 2025, replaced the 1970 Code of Professional Ethics after more than half a century, and to its credit, the drafters clearly saw this moment coming. Rule 1.19, “Technological Competence and Diligence,” has no counterpart in either the old 1970 Code or the ABA Model Rules; it was written specifically to extend the duty of competence under Rule 1.1 to cover technology, including, by clear implication, the responsible use of AI drafting tools. Rule 5.3 imputes an attorney’s ethical duties onto the work of non-lawyer assistance, which reaches AI output the same way it would a paralegal’s draft. Rule 3.3 preserves candor to the tribunal regardless of whether an error originated in software or in a lawyer’s own hand, a live issue, given the growing docket of AI-hallucinated citations surfacing in courts on both sides of the Atlantic.
What our rules do not do, because nothing in Puerto Rico’s regulatory architecture allows it, is authorize the entity. Every rule we have reaches only the natural person: the attorney or the notary. A Garfield-style platform operating here would have no lawful path to be the regulated party. It would have to sit entirely behind an individual attorney’s license, a materially more constrained model than what the SRA now permits.
That gap is worth naming plainly, because the population Garfield served is not incidental. Small debt claims, unpaid invoices, modest fee disputes: these are the cases where the cost of retaining conventional counsel routinely exceeds the amount in controversy, so people write off what they’re owed rather than sue. That is squarely an access-to-justice problem in Puerto Rico too, and it is one our current framework is not structurally positioned to solve at scale, however well Rule 1.19 anticipates the ethical questions an individual attorney using AI tools would face.
None of this argues for importing the ABS model wholesale, nor for treating regulatory caution as an obstacle. The concerns that make entity-level licensing hard are real: preserving professional independence; ensuring supervisory accountability actually functions rather than becoming a rubber stamp; and protecting client confidentiality inside a technology stack a lawyer doesn’t fully control. The SRA’s own commentary on the Garfield decision makes clear that British regulators are still working through them case by case.
But the question of whether Puerto Rico’s disciplinary framework should ever reach beyond the individual practitioner to the platform itself is one our judiciary and our bar associations should be studying now, deliberately, rather than reacting to it after a comparable case arrives at our own courts without any rule contemplating it. Rule 1.19 was the right first move. It will not be the last one this technology requires of us.
The views expressed do not represent the institutional position of the Judicial Branch as provided under Canon 24 of Judicial Ethics, and are shared in strict adherence to and pursuant to the authority conferred by Canon 25 of Judicial Ethics upon the President of the Puerto Rico Judges’ Federation.
