Torres Campos v. Munoz: a published California appellate opinion sanctions a lawyer $5,000 for citing AI-hallucinated cases in a dog-custody fight (2026)

The problem

Joan Pablo Torres Campos and Leslie Ann Munoz, former domestic partners, fought over shared custody and visitation of a dog. As the court put it, Torres “appeals from a family court order denying his request for shared custody and visitation of a dog.” This story is not about who got the dog — the appellate court affirmed the order. It is about the fake law that entered the case.

Munoz’s counsel, Roxanne Chung Bonar, cited two California cases for the proposition that a ruling should weigh the “emotional well-being and stability of the parties”: Marriage of Twigg (1984) 34 Cal.3d 926 and Marriage of Teegarden (1995) 33 Cal.App.4th 1572. Neither exists. The same fictitious authorities then made it into the family court’s own written order — which the court had directed the parties to draft — and Bonar repeated and defended them in her filings with the Court of Appeal.

What was built

Pressed on where the fabricated citations came from, Bonar could not say. The opinion records that “she did not have a paid subscription to a legal research service at the time, and she was using other online resources including AI for this purpose. She also conceded she may have obtained fictitious information about Twigg and Teegarden using AI tools.” No specific AI product is named in the opinion — the court’s finding rests on counsel’s own qualified concession, not on an identified tool.

The panel treated the episode as emblematic of a wider problem. It expressly published the opinion “to emphasize that courts and attorneys alike have a responsibility to protect the legal system against distortion by fabricated law, particularly in this new era of hallucinated citations generated by artificial intelligence (AI) tools.”

The outcome

Filed March 5, 2026 and certified for publication, the opinion (Buchanan, J., with Irion, Acting P.J., and Do, J., concurring) affirmed the underlying order but sanctioned opposing counsel. The court held that “relying on fictitious legal authority is sanctionable conduct because it constitutes an unreasonable violation of the rules,” invoking its power under California Rules of Court, rule 8.276(a)(4).

The decretal terms:

We will therefore impose sanctions in the amount of $5,000.

Respondent’s counsel Roxanne Chung Bonar is ordered to pay $5,000 in sanctions payable to the clerk of this court no later than 30 days after the remittitur issues.

The order also directs the clerk to forward the opinion to the State Bar of California and requires Bonar to personally report the sanction to the State Bar. The $5,000 is the sole monetary sanction; a separate “$1,500” figure in the opinion is a comparator drawn from another case (Alvarez), not part of this award.

Two independent newsrooms carry the $5,000 and the AI concession firsthand. The ABA Journal (March 9, 2026) reported that “the justices also imposed $5,000 in sanctions against Bonar” and that “she was using online resources, including artificial intelligence, to conduct her legal research.” Techdirt (March 16, 2026) reported that “the court was not amused. It hit Bonar with $5,000 in sanctions,” and that she “conceded she may have obtained fictitious information about Twigg and Teegarden using AI tools.”

Verification status: PENDING — checker-graduated (confidence 1.000), awaiting HUMAN client-confirmation. NOT verified.

Path to green

This is a court-adjudicated public record; no client-confirmation call applies. The critical facts are byte-tied to the official California slip opinion (D085584) and corroborated by two independent newsrooms. The only remaining human step before a green badge is to confirm the sanction still stands as recorded — that the $5,000 was paid within 30 days of the remittitur and was not later modified, vacated, or reversed (e.g., on rehearing or California Supreme Court review), and that the State Bar referral proceeded.