Joan Pablo Torres Campos v. Leslie Ann Munoz

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

therefore affirm the family court’s order. III We next consider whether to impose sanctions against Bonar for citing and relying on fictitious legal authorities in her oppositions to the motions to reinstate this appeal. Business and Professions Code section 6068, subdivision (d), states it is the duty of an attorney “[t]o employ . . . those means only as are consistent with truth, and never to seek to mislead the judge or any judicial officer by an artifice or false statement of fact or law.” California Rules of Professional Conduct, rule 3.3(a)(1) and (2), prohibit an attorney from “knowingly mak[ing] a false statement of fact or law to a tribunal or fail[ing] to correct a false statement of material fact or law previously made to the tribunal by the lawyer” or “knowingly misquot[ing] to a tribunal the language of a book, statute, decision or other authority.” A person’s knowledge may be inferred from the circumstances. (Cal. Rules Prof. Conduct, rule 1.0.1(f).) We may impose sanctions against appellate counsel for committing any unreasonable violation of the California Rules of Court. (Cal. Rules of Court, 17 rule 8.276(a)(4).) Relying on fictitious legal authority is sanctionable conduct because it constitutes an unreasonable violation of the rules requiring that each point be supported by actual legal authority (id., rule 8.204(a)(1)) and prohibiting citation of unpublished authorities (id., rule 8.1115(a)). (Shayan v. Shakib (2025) 116 Cal.App.5th 619, 624–625 (Shayan); Schlichter v. Kennedy (2025) 116 Cal.App.5th 24, 31–34 (Schlichter); People v. Alvarez (2025) 114 Cal.App.5th 1115, 1118–1120 (Alvarez); Noland, supra, 114 Cal.App.5th at pp. 443–447.) 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 the 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. “[I]t is a fundamental duty of attorneys to read the legal authorities they cite in appellate briefs or any other court filings to determine that the authorities stand for the propositions for which they are cited.” (Noland, supra, 114 Cal.App.5th at p. 445.) “[T]he rules of this court impose on attorneys the obligation to assure that filings they sign do not falsely represent the holdings of cases.” (Shayan, supra, 116 Cal.App.5th at p. 624.) Making matters worse, even 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, reported at 34 Cal.3d 926, 195 Cal.R

Authorities cited in the passage: Marriage of Twigg · emotional well‑being in custody; Twigg does not exist and the citation · In re Marriage of Teegarden · Shayan v. Shakib · Schlichter v. Kennedy · People v. Alvarez