Joan Pablo Torres Campos v. Leslie Ann Munoz
CA California · Mar 5, 2026
- Jurisdiction
- state
- Court
- CA California
- Record ID
- joan-pablo-torres-campos-v-leslie-ann-munoz-2026-03-05
- Observed outcome
- The court affirmed the underlying order and imposed a $5,000 sanction on respondent's counsel, payable to the court clerk, with a mandatory referral to the State Bar.
- Known monetary consequence
- $5,000
Why this matter warrants attention
The court imposed a $5,000 monetary sanction and a mandatory referral to the State Bar of California against attorney Roxanne Chung Bonar for citing and persistently defending fictitious legal authorities, including cases potentially generated by AI tools.
Fabricated: Case Law | Court and counsel cited 'Marriage of Twigg' as authority on prioritizing parties' emotional well‑being in custody; Twigg does not exist and the citation "34 Cal.3d 926" and parallel citations provided by counsel were fabricated. Court found reliance on this nonexistent authority and counsel later admitted Twigg was fictitious. || Misrepresented: Case Law | Counsel cited 'In re Marriage of Teegarden' with an incorrect citation/year and attributed a holding about emotional well‑being and pet custody that the real 1986 Teegarden decision did not hold; the citation and asserted holding were misrepresented.
A single fictitious case plus a misquoted real one triggers a $5K fine and bar referral; mandate partner sign-off on every cited authority.
Failure modes and consequences
- Fake Citations
- Misrepresented Authority
- Bar Referral
- Family
- Appellate
- Monetary
- AI attribution
- Implied
- Recorded tool
- Unidentified AI tools
- Known monetary consequence
- $5,000
- Procedural posture
- Appellate review of a family court order regarding pet custody, involving an order to show cause regarding sanctions for attorney misconduct.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Counsel conceded at oral argument that she may have used AI tools.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Train lawyers and staff to identify and verify generated legal content.
- Assign a responsible reviewer for AI-assisted research and drafting.
- Retain a matter-level record of source checks and corrections.