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May 4, 2026

Bad AI citations: The 'crimes'

A recent California Court of Appeal opinion in In re Domestic Partnership of Torres Campos & Munoz exposes how lawyers, and even a trial court, relied on fictitious AI-generated legal citations in a pet custody dispute--leading the appellate court to condemn the conduct as a serious breakdown in professional responsibility across counsel and the bench.

Myron Moskovitz

Legal Director
Moskovitz Appellate Team

90 Crocker Ave
Piedmont , CA 94611-3823

Phone: (510) 384-0354

Email: myronmoskovitz@gmail.com

UC Berkeley SOL Boalt Hal

Myron Moskovitz is author of Strategies On Appeal (CEB, 2021; digital: ceb.com; print: https://store.ceb.com/strategies-on-appeal-2) and Winning An Appeal (5th ed., Carolina Academic Press). He is Director of Moskovitz Appellate Team, a group of former appellate judges and appellate research attorneys who handle and consult on appeals and writs. See MoskovitzAppellateTeam.com. The Daily Journal designated Moskovitz Appellate Team as one of California's top boutique law firms. Myron can be contacted at myronmoskovitz@gmail.com or (510) 384-0354. Prior "Moskovitz On Appeal" columns can be found at http://moskovitzappellateteam.com/blog.

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Bad AI citations: The 'crimes'
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A recent appellate opinion deals with a disease that should have been killed in the cradle but instead seems to be growing: lawyers--and now judges--using AI to find non-existent cases that support their arguments.

Here's my summary of what happened in In Re Domestic Partnership of Torres Campos & Munoz (2026)118 Cal.App.5th 1112. Sorry it's so long, but the details are important. All of the following comes from the appellate court's op...

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