Citation Laundering: How fake cases gain legitimacy by passing through real legal documents

I was deep in the outline for an ethics seminar, the kind where you want crisp hypotheticals and maybe a touch of drama, when a colleague forwarded me a published opinion from the Fourth District. "You're going to want to read this," she wrote. No further context.

She was right.

In re Domestic Partnership of Campos & Munoz (D085584) is, on its surface, a case about a dog. Specifically, it is about a dog named Kyra, and whether her former co-owner was entitled to shared custody and visitation after the dissolution of his domestic partnership. That is already an interesting area of law: Family Code section 2605 gives courts discretion to make orders about household pets in dissolution proceedings, treating them not as mere property but as something closer to dependents. Pet custody litigation is a genuine and growing field, and the question of what factors a court should weigh under section 2605 is unsettled enough to be worth a published opinion.

That question, however, never gets answered in Torres Campos. The case was swallowed whole by something far stranger: a cascade of fabricated legal authority that began with a Reddit blogger named Sassafras Patterdale. The court describes Sassafras as "a blogger, podcaster, and animal rescuer, who writes about divorce, custody, and the messy, beautiful lives we weave." Their Reddit article about pet custody battles cited Marriage of Twigg (1984) 34 Cal.3d 926 as a "watershed" case. A paralegal friend sent it to the client. The client brought it to a family dinner. The client's cousin, an attorney, was there. And from that dinner table, Twigg began its journey through the California legal system.

By the time the Court of Appeal was done, there were $5,000 in sanctions, a State Bar referral, and a published opinion that reads, in stretches, like a judicial expression of stunned disbelief.

Kyra, presumably, remains with Munoz. The bigger questions belong to all of us.

The provenance chain

Marriage of Twigg is not a real case. The citation Sassafras provided belongs to a criminal matter having nothing to do with pets or custody. From the Reddit article, Twigg passed into the client's declaration, where it was cited for the proposition that courts must prioritize the mental health of the primary custodian. It then passed into the trial court's written order--drafted by Torres's own counsel, who never checked whether the case was real. The court signed the order. The fiction was now official.

Each person in the chain accepted the citation because the last person had. No one verified it. No one read the case. They simply passed it forward, trusting that its presence in an official document was warrant enough.

The escalation

What elevates Torres Campos above the routine AI hallucination sanction case is what happened after the fiction was exposed. When Torres's counsel finally identified Twigg as invented, in a second motion to reinstate the appeal, attorney Roxanne Chung Bonar did not acknowledge the error. She doubled down.

Her opposition called the accusation "baseless" and "a grave accusation." She declared Twigg to be "a legitimate California Supreme Court case, reported at 34 Cal.3d 926, 195 Cal.Rptr. 718, 670 P.2d 340, decided on July 5, 1984." She accused opposing counsel of "incompetence" and "inadequate database searches or unfamiliarity with standard legal reporters."

Every word of this was false. The parallel reporter citations were also fabricated. They correspond to no real decision. At oral argument, Bonar acknowledged she had no paid subscription to a legal research service and had been using AI tools for research. She conceded she "may have" used AI to generate the additional citation information for Twigg.

She had apparently gone back to the same well that produced the problem and drawn up another bucket of fiction to defend the first.

The duty to read what you cite

The court's statement of attorney responsibility should be committed to memory by anyone who files papers in a California court: "Simply stated, no brief, pleading, motion, or any other paper filed in any court should contain any citations ... that the attorney responsible for submitting the pleading has not personally read and verified." The court was quoting Noland v. Land of the Free, L.P. (2025) 114 Cal.App.5th 426.

This is not a new obligation. An attorney citing a case has always been vouching for it: representing that it exists, that it says what counsel claims, that it supports the proposition offered. AI hallucinations have not created this duty. They have simply made the consequences of ignoring it more visible and more severe.

The court extended the obligation to the bench as well. It stated plainly that it is "imperative for both the court and the parties to verify that the citations in all orders are genuine." A judge's signature on a proposed order is not a clerical act. It is an endorsement. Particularly in busy family law calendars, where proposed orders after hearing are routine, judges cannot assume that the citations in submitted orders have been verified by anyone. Torres Campos is proof of what happens when everyone assumes someone else checked.

The laundering problem

Torres Campos illustrates a dynamic that deserves a name: citation laundering. A fabricated authority acquires institutional patina the moment it enters a legitimate document such as a client declaration or trial court order. The next person in the chain no longer sees a Reddit post. They see a citation that has already passed through the legal process. Surely the court checked it. Surely opposing counsel verified it. The fiction accumulates credibility precisely because no one treats verification as their own responsibility.

Bonar said it plainly in her response to the order to show cause: she "mistakenly assumed that, because these materials were part of the Superior Court's official record, the citations had already been vetted and could be relied upon as accurate." That assumption is understandable. It is also exactly wrong.

Property law has long recognized the bona fide purchaser, the innocent buyer who takes clean title by relying in good faith on the apparent state of the record. We protect that buyer because commerce depends on reasonable reliance. No equivalent doctrine exists for legal citations, nor should one. The duty to verify is personal and non-delegable. Apparent legitimacy in the official record is not a warranty. Every attorney who incorporates a citation into a filing is vouching for it, regardless of where it came from or how many documents it has already passed through.

A fabricated case is void ab initio. No amount of official handling changes that. Each transfer looks clean because it rests on what came before, but the chain of transmission doesn't clean the citation. It only obscures that there was never anything there to begin with.

The forfeiture ruling captures this mechanism with particular precision. Torres's own counsel drafted the proposed order, incorporated the fake citations, and submitted it without checking whether the cases were real. The court signed. The fictional cases now lived in an official judicial order. When Bonar was later challenged, she pointed to their presence in the record as evidence of their legitimacy. The court was unpersuaded. Torres forfeited his claim not because the citations were valid, but because his own attorney had transmitted them, without verification, into the official record.

The defense against citation laundering is not sophisticated. It is the oldest professional obligation in law, taken seriously: read what you cite. The mechanism fails the moment anyone in the chain stops and checks. In Torres Campos, no one did--until the Court of Appeal.

Sanctions and what comes next

The court imposed $5,000 in sanctions against Bonar and referred the matter to the State Bar, noting she persisted after being alerted and remained evasive about the source of her additional fabricated citations. The footnote 3 recommendation for Judicial Council guidelines on citation verification is no longer purely aspirational. Standard of Judicial Administration 10.80, effective Sept. 1, 2025, already advises judicial officers to verify that generative AI material "prepared on their behalf by others" is accurate and to correct any hallucinated output. This language speaks to the situation where counsel drafts and submits a proposed order. SB 574, currently pending in the Assembly, would impose a parallel verification obligation on attorneys by statute. Torres Campos is a useful reminder of why both are necessary.

Conclusion

Torres Campos is about a dog. But the dog is almost beside the point. The case is really about what happens when everyone in a legal proceeding treats verification as someone else's job--when a citation travels from a Reddit article to a family dinner to a client declaration to a trial court order to an appellate brief, and no one, at any stop along the way, asks whether the case is real.

Every attorney who submits a brief, and every judge who signs an order, is a checkpoint. No document a fabricated case passes through can give it validity--only the appearance of validity. AI has made fabricated citations easier to produce and harder to detect. It has not changed the obligation to verify. It has only made that obligation more urgent.

Verify the citation. Read the case.

Disclaimer: The views expressed in this article are solely those of the author in their personal capacity and do not reflect the official position of the California Court of Appeal, Second Appellate District, the Judicial Council of California, or the Judicial Branch of California. This article is intended to contribute to scholarly dialogue and does not represent judicial policy or administrative guidance.