In re the Domestic Partnership of Torres Campos & Munoz (Torres Campos v. Munoz)
California Court of Appeal, Fourth Appellate District, Division One · Cal. Ct. App. · California bar guidance
Verified May 5, 2026
- Citation
- In re Domestic Partnership of Torres Campos & Munoz, No. D085584 (Cal. Ct. App., 4th Dist., Div. 1, Mar. 5, 2026) (certified for publication)
- Decided
- March 5, 2026
Summary
Respondent's counsel Roxanne Chung Bonar cited the fictitious authority "Marriage of Twigg (1984) 34 Cal.3d 926" and a fabricated version of "Marriage of Teegarden (1995) 33 Cal.App.4th 1572" in oppositions to motions to reinstate the appeal, arguing these cases supported prioritizing the parties' emotional well-being in pet custody. After opposing counsel flagged the citations as fake, Bonar doubled down, supplying additional fabricated parallel citations and a bogus decision date. At oral argument she conceded the additional citation information "may have" come from her use of AI tools. Justice Buchanan, joined by Acting P.J. Irion and Justice Do, imposed sanctions.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $5,000
What sanction did the court impose?
$5,000 in sanctions payable to the clerk of the court within 30 days of remittitur, with mandatory referral to the State Bar of California under Business and Professions Code section 6086.7. Bonar was also ordered to personally report the sanctions to the State Bar. The underlying family court order denying pet custody was affirmed on forfeiture grounds.
Why does In re the Domestic Partnership of Torres Campos & Munoz (Torres Campos v. Munoz) matter for law firms using AI?
This published Fourth District opinion is notable on two fronts: it imposes a $5,000 sanction (substantially higher than the $1,500 to $1,750 awards in earlier California fake-citation cases like Alvarez and Schlichter) because counsel persisted after being alerted to the fabrication, and it expressly faults the appellant’s own counsel for forfeiting the merits issue by drafting and submitting a proposed order containing the fictitious citations without verifying them. For managing partners, the case is a reminder that the duty to verify cited authority attaches to proposed orders prepared at a court’s direction, not just briefs, and that compounding an unverified AI citation with a defensive follow-up filing materially escalates the sanction.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.