Monday, March 9, 2026
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C.A. Imposes $1,500 Sanction for Citing Fake Cases
Then-Court Commissioner, Opposing Counsel Faulted for Not Noticing Fakery
By a MetNews Staff Writer
A then-San Diego Superior Court commissioner, who has since been appointed to a judgeship, and the attorney for the petitioner in a dissolution of domestic partnership matter failed to notice that cases cited by the lawyer for the respondent were fabrications, prompting Div. One of the Fourth District Court of Appeal to declare them neglectful and to impose a $5,000 sanction on the lawyer who represented the supposed decisions to be governing jurisprudence.
Justice Martin N. Buchanan, who authored Thursday’s opinion, made note that the sanctioned lawyer, Los Alamitos sole practitioner Roxanne Chung Bonar, continued to cite the made-up decisions in appellate filings. The justice called upon ethics bodies to adopt verification rules.
The invented cases were referenced in an order dealing with pet visitation that was drafted by the respondent’s attorney, and approved by the commissioner. They assumed the fake cases, repeatedly mentioned by the petitioner’s lawyer, to be real.
The respondent, Joan Pablo Torres Campos (referred to in the opinion as “Torres”), later sought to vacate the decree on appeal on the ground that the authorities were fake, arguing:
“Upon diligent investigation by appellant’s counsel, these cases have been determined to be entirely fictitious. Searches of Westlaw, Lexis, and Google Scholar reveal no cases with these citations, parties, or holdings.”
Buchanan, whose opinion was joined in by Acting Presiding Justice Joan K. Irion and Justice Truc T. Do, acknowledged that “it is an abuse of discretion for a court to rely in material part on fictional case authorities in…making an order” but said that, “[i]n the highly unusual circumstances of this case,…we conclude that [the appellant] forfeited this claim of error” by drafting the decree and failing to raise the fabrication issue.
Responsibility Emphasized
Addressing the bogus citations, Buchanan added:
“We publish this 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. In a system of precedents that is designed to achieve consistency, predictability, and adherence to the rule of law, the judiciary cannot function properly unless judges and lawyers confirm the authenticity of cited authorities and review them to evaluate their holdings and reasoning. When the participants fail to perform this basic function, it compromises these institutional values and diminishes faith in the judicial process.”
In a footnote, he added:
“To address the emergence of AI-generated fake citations, we recommend that the Judicial Council or other appropriate committees consider adopting guidelines or rules for judges and attorneys on verification of citations, particularly those in orders drafted by the parties and submitted to the court for signature.”
Fabricated Cases
The fabricated cases were first cited by Bonar, in representing her cousin, respondent Leslie Ann Munoz, in opposing a 2024 request made in family court by her former domestic partner, Joan Pablo Torres Campos (referred to in the opinion as “Torres”), for shared custody of a dog named Kyra. Final judgment in the dissolution proceedings had been entered two years earlier without any mention of pet visitation.
In a letter addressed to Torres, Bonar pointed to two fake cases, writing:
“We will rely on established case law to support our position: Marriage of Twigg (1984) 34 Cal.3d 926, the court held that the emotional well-being and stability of the parties involved are crucial considerations in custody determinations…In addition to Twigg, we also rely on Marriage of Teegarden (1995) 33 Cal.App.4th 1572, where the court held the importance of maintaining stability for the dependent parties involved.”
Munoz cited the invented Twigg decision in a declaration in support of her opposition, and Torres failed to point out that the case does not exist. The parties on Sept. 19, 2024 stipulated to have then-San Diego Superior Court Commissioner Lizbet Muñoz (who was appointed to a judgeship by Gov. Gavin Newsom on Dec. 16, 2024) hear the matter.
After the hearing, the commissioner directed Torres to submit a formal order to conform to the oral rulings. She approved the decree he submitted, which cited the fabricated Twigg and Teegarden cases as standing for the proposition that the court must take the well-being and stability of the parties into consideration when deciding pet visitation and declared:
“Based on the testimony of Ms. Munoz and her mental state…, the Court finds it is not in the best interests of the parties[’] mental stability for them to continue to interact with each other, and thus denies pet Custody.”
Buchanan’s Opinion
Addressing the merits of the appeal, Buchanan said:
“We have no difficulty concluding that it is an abuse of discretion for a court to rely in material part on fictional case authorities in rendering a decision or making an order. Reliance on fake cases is fundamentally incompatible with an informed exercise of discretion controlled by genuine principles of law. It seriously undermines the integrity of the outcome and erodes public confidence in our judicial system. It can also hinder meaningful appellate review….Although we appreciate that trial courts must often rely on the parties to prepare written orders, it is imperative for both the court and the parties to verify that the citations in all orders are genuine and truly stand for the propositions cited. This is especially vital with the increasing incidence of hallucinated case citations generated by AI tools.”
He went on to say:
“Although Munoz and Bonar were responsible for improperly citing these fictitious authorities in the first place, Torres’s own counsel affirmatively drafted and submitted the proposed order with these citations that was ultimately signed by the family court. And even though his own counsel drafted the order, Torres failed to object to the court’s reliance on these citations or call the court’s attention to the issue. The forfeiture rule applies to a party’s failure to object to the language of a proposed order when it had an opportunity to do so.”
Addresses Sanctions
As to sanctions, Buchanan said:
“Bonar admits that she cited fictitious authority to the court, including the fictional Teegarden case apparently generated by AI and the nonexistent Twigg case discussed in [a] Reddit article that was authored by a non-attorney blogger. She also admits she did not verify this authority. For an attorney to cite and rely on a fictional case obtained from a Reddit article or an AI prompt without verifying and reading the case itself is an unreasonable violation of the Rules of Court..”
He continued:
“[E]ven after counsel for Torres pointed out that Twigg was an invented case in his second motion to reinstate the appeal, Bonar doubled down. She continued to insist it was a ‘valid, published precedent[]’ and a ‘legitimate California Supreme Court case….’ Until Bonar filed this opposition, no one had previously supplied [the] additional fake citations…or the bogus date of decision….This additional citation information was just as phony as the original citation. Yet Bonar in the same document accused opposing counsel of ‘incompetence’….”
Misconduct Aggravated
Citing cases in which courts of appeal have sanctioned attorneys $1,500 for similar conduct, he said that “Bonar’s conduct [is] significantly more serious” because she “aggravated the misconduct by providing additional fictitious citation information” and “has not explained” how she came up with that new data “other than to concede at oral argument that it ‘may have’ come from her use of AI tools.”
The jurist declared:
“The order is affirmed….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….[T]he clerk of this court is directed to forward a copy of this opinion to the State Bar of California upon issuance of the remittitur….Bonar is also ordered to personally report the sanctions to the State Bar of California.”
San Diego Superior Court records identify Bonar as Leslie Ann Munoz’s attorney but do not list any counsel of record for Torres. On appeal, Torres was represented by family law practitioner David C. Beavans.
The case is In re Domestic Partnership of Campos and Munoz, 2026 S.O.S. 611.
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