Pineda v. Campos
Arizona Court of Appeals, Division One · Ariz. Ct. App. · Arizona bar guidance
Verified September 30, 2026
- Citation
- Pineda v. Campos, No. 1 CA-CV 24-0912 FC (Ariz. Ct. App. Aug. 7, 2025) (mem. decision)
- Decided
- August 7, 2025
Summary
Attorney Kamille R. Dean, representing the appellant husband in an order-of-protection appeal, filed a brief that the Court of Appeals found contained fabricated quotations attributed to several Arizona cases and citations whose reporter information pointed to entirely unrelated opinions. The court documented that "Cardoso v. Soldo, 230 Ariz. 454 (App. 2012)" used reporter information actually corresponding to Lund v. Myers, 230 Ariz. 445 (App. 2012), and that a citation to "Leon v. Plaza, 251 Ariz. 575 (App. 2021)" pointed instead to Jessie D. v. Department of Child Safety. Quotations attributed to Savord v. Morton and Arjona v. Arjona did not appear in those decisions, and the Arjona memorandum decision had been vacated. Presiding Judge Jennifer M. Perkins, joined by Vice-Chief Judge David D. Weinzweig and Judge Cynthia J. Bailey, called the citation errors "egregious."
- AI tool:
- Unidentified (the decision finds fabricated quotations and citations whose reporter pages point to unrelated opinions, but does not mention AI or name a tool)
What sanction did the court impose?
The court referred the decision to the State Bar of Arizona to determine whether counsel violated the rules of professional conduct, and imposed costs on appeal against Husband's counsel personally as a sanction under ARCAP 25 for misrepresentations of the record and misleading citations to legal authorities in violation of ARCAP 13(a)(7). No fixed monetary amount was set in the opinion: costs are to be calculated upon Wife's compliance with ARCAP 21(b).
Why does Pineda v. Campos matter for law firms using AI?
Pineda v. Campos shows that citation failures of the kind associated with AI drafting now reach routine family-law appeals, not just federal civil dockets, though the decision itself does not mention AI. The court did not need to find how the citations were produced to act: fabricated quotations, citations whose reporter pages mapped to unrelated cases, and reliance on a vacated memorandum decision were enough to trigger a State Bar referral and shift appellate costs to counsel personally. For managing partners, the operational lesson is that a single brief with unverified citations can produce both a bar inquiry and personal liability for opposing-party costs, regardless of whether AI use is admitted on the record.
Sources
Primary sources
- AI attribution is a tracker inference. The decision never mentions artificial intelligence; it describes the defects as misrepresentations of the record and misleading citations to legal authority.
- Monetary amount: the opinion awards costs as a sanction but does not fix a dollar amount; final figure depends on Wife's ARCAP 21(b) statement of costs.