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

Two former domestic partners, Joan Pablo Torres Campos and Leslie Ann Munoz, fought in California family court over shared custody and visitation of a dog, and the appellate court framed the appeal in exactly those terms: “Torres appeals from a family court order denying his request for shared custody and visitation of a dog” (source). This case is not about who kept the dog; the Court of Appeal affirmed the underlying order (source). It is about the fabricated law that entered the record.

What was built

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

Pressed on where the fabricated citations came from, Bonar could not say. The opinion records: “At oral argument, Bonar claimed she could not remember where this additional fictitious citation information came from. She acknowledged 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” (source). 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 (source).

The panel treated the episode as emblematic of a wider problem, publishing 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” (source). Independent coverage adds that the original Twigg reference traced to a Reddit article a friend had passed to Munoz, and that Bonar then “doubled down” with additional fictitious citations that did not come from that article (source).

The outcome

Decided 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, holding that relying on fictitious legal authority is sanctionable under California Rules of Court, rule 8.276(a)(4) (source).

The sole monetary sanction: $5,000. The decretal order reads: “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” (source). The order also directs the clerk to forward the opinion to the State Bar of California under Business and Professions Code section 6086.7, subdivision (a)(3) (source).

A separate $1,500 figure in the opinion is a comparator, not part of this award. It comes from another case the panel cited: “In Alvarez, we imposed sanctions of $1,500 against counsel for citation of fabricated authority” (source). The court set Torres Campos higher because Bonar aggravated the misconduct (source).

Two independent newsrooms carry the figure and the AI concession firsthand. The ABA Journal reported that “the justices also imposed $5,000 in sanctions against Bonar” and that “during oral argument, Bonar admitted that she was using online resources, including artificial intelligence, to conduct her legal research” (source). Techdirt reported that “the court was not amused. It hit Bonar with $5,000 in sanctions, significantly more than the $1,500 that the same court imposed in a recent similar case” (source).

How this was verified

This case carries a green badge under TIN’s current standard: independently validated by TIN against the public record. The critical facts, the $5,000 sanction, rule 8.276(a)(4), the 30-day-from-remittitur payment term, the State Bar referral, and the AI concession, were read on 2026-08-03 against the FindLaw reprint of the official California slip opinion (D085584), which is a Tier-1 primary, and corroborated firsthand by two independent Tier-2 newsrooms (ABA Journal and Techdirt). The honest limits: no specific AI product is named, so the tool attribution rests on counsel’s own qualified concession, not on an identified product; and the $1,500 figure is a comparator from another case, kept out of this award. No later disposition modifying, vacating, or reversing the sanction was found on the public record as of the live check.

Related case files

The clearest parallel is Noland v. Land of the Free, the first published California Court of Appeal opinion to sanction AI-fabricated citations; Torres Campos is the same court returning to the same duty a year on, with a larger fine for aggravated conduct. Garner v. Kadince shows a different appellate court, Utah, also choosing to publish so the sanction sets precedent rather than staying a private rebuke. Wadsworth v. Walmart lands on the same $5,000 figure through a federal route, Rule 11 rather than a state appellate rule, which is a useful check on how courts price the same misconduct across systems.

Sources

Tier 1 = the court’s own published opinion; Tier 2 = independent press naming the parties. Each figure was checked against the live source on 2026-08-03.

1. Court of Appeal, Fourth Appellate District, Division One (California), “In re the Domestic Partnership of Torres Campos & Munoz,” No. D085584, decided 2026-03-05 (Tier 1, published slip opinion, read via the FindLaw reprint of the official text). https://caselaw.findlaw.com/court/ca-court-of-appeal/118194944.html
2. ABA Journal, “California appeals court upholds trial order citing hallucinated cases,” 2026-03-09 (Tier 2, independent legal newsroom carrying the $5,000 sanction and AI concession firsthand). https://www.abajournal.com/news/article/california-appeals-court-upholds-trial-order-citing-hallucinated-cases
3. Techdirt, “A Reddit post, an AI hallucination, and two lawyers who never checked citations walk into a dog custody case,” 2026-03-16 (Tier 2, independent newsroom carrying the $5,000 and $1,500 comparator firsthand). https://www.techdirt.com/2026/03/16/a-reddit-post-an-ai-hallucination-and-two-lawyers-who-never-checked-citations-walk-into-a-dog-custody-case/