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Mar. 11, 2026

Commissioner, now judge, approved order with fake AI case citations

A Court of Appeal panel sanctioned a lawyer $5,000 for repeatedly citing fabricated cases in a dog custody dispute but also warned that judges must verify authorities before signing orders. The ruling notes that a San Diego commissioner, now a Superior Court judge, approved an order containing the fake citations.

Commissioner, now judge, approved order with fake AI case citations
Justice Martin N. Buchanan

A San Diego family court commissioner who is now a Superior Court judge approved a pet visitation order containing fabricated case citations -- an error the 4th District Court of Appeal said highlights the growing danger of AI-generated legal research that goes unchecked by lawyers and courts.

Justice Martin N. Buchanan, writing for a unanimous panel, said the order relied in part on two nonexistent cases cited by counsel and signed by then-Commissioner Lizbet Munoz. The appellate...

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