{"id":107,"date":"2026-03-05T12:00:00","date_gmt":"2026-03-05T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=107"},"modified":"2026-03-05T12:00:00","modified_gmt":"2026-03-05T12:00:00","slug":"campos-munoz-pet-custody-ai-fake-citations-sanctions","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=107","title":{"rendered":"Domestic Partnership of Campos & Munoz \u2014 $5,000 in sanctions imposed for citing AI-generated fake cases in pet custody dispute"},"content":{"rendered":"
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Case<\/dt>\n
In re Domestic Partnership of Campos & Munoz<\/dd>\n
Court<\/dt>\n
4th District Court of Appeal<\/dd>\n
Date Decided<\/dt>\n
2026-03-05<\/dd>\n
Docket No.<\/dt>\n
D085584<\/dd>\n
Status<\/dt>\n
Reported \/ Citable<\/dd>\n
Topics<\/dt>\n
Pet custody, Family Code section 2605, AI hallucinated citations, attorney sanctions, duty of candor, Business and Professions Code section 6086.7, California Rules of Professional Conduct<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Joan Pablo Torres Campos and Leslie Ann Munoz dissolved their domestic partnership in San Diego in 2022. The dissolution judgment said nothing about the parties’ dog, Kyra. Two years later, Torres filed a request for order under Family Code section 2605, which authorizes a family court to award sole or joint ownership of a community property pet animal based on the care of the animal, asking for shared custody and visitation.<\/p>\n

Munoz was represented pro bono by her cousin, attorney Roxanne Chung Bonar. Bonar opposed the request and submitted papers citing two purported published opinions, “Marriage of Twigg (1984) 34 Cal.3d 926” and “Marriage of Teegarden (1995) 33 Cal.App.4th 1572.” Both citations turned out to be fabricated. The Twigg citation pointed to a real but unrelated criminal case, and the real Teegarden case was from 1986 and dealt with spousal support, not pets.<\/p>\n

The family court denied the request for shared pet custody. The order, however, repeated the same fictitious authorities. Torres’s counsel had drafted the proposed order, citing the same fake cases that opposing counsel had originally invoked. On appeal, Torres argued the family court committed reversible error by relying on fictitious authorities and asked the appellate court to reverse and adopt a new multi-factor test for pet custody.<\/p>\n

The Court’s Holding<\/h2>\n

The Fourth District Court of Appeal, Division One, affirmed the family court’s order but issued a published opinion focused on the broader problem of artificial intelligence hallucinated citations in legal filings. As to the merits, the court held that Torres had forfeited the claim of error because his own counsel drafted the proposed order containing the fictitious cases and never alerted the family court that they were fake. The record was also inadequate to evaluate Torres’s proposed multi-factor test under Family Code section 2605.<\/p>\n

The court’s most consequential ruling concerned attorney conduct. The court issued an order to show cause why Bonar should not be sanctioned. In her response, Bonar admitted she had used a Reddit post and AI-generated material in preparing her papers. Even after Torres’s counsel pointed out that the cited cases did not exist, she insisted the Twigg case was a legitimate California Supreme Court decision and provided additional supposed citation details that turned out to be just as fabricated. She also accused opposing counsel of incompetence for failing to find them.<\/p>\n

The court held that Bonar’s conduct violated the duty of candor under the California Rules of Professional Conduct and the Rules of Court. Citing prior decisions in Alvarez and Schlichter that imposed $1,500 and $1,750 in sanctions for similar conduct, the court found Bonar’s misconduct more serious because she persisted in defending the fabricated authorities and never fully explained the source of the additional fake citation information. The court imposed $5,000 in sanctions and ordered the matter reported to the State Bar of California under Business and Professions Code section 6086.7.<\/p>\n

Key Takeaways<\/h2>\n