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Commentary: How a custody fight over an old dog showed why lawyers should never trust AI to tell the truth
The seemingly limitless proliferation of cases in which lawyers have been caught letting fictitious AI-generated legal citations contaminate their briefs continues to amaze.
That’s not only because judges are fining more lawyers for their laziness, but because the publicity about these embarrassments has been inescapable.
Here’s one involving a dog named Kyra.
She’s a 16-year-old Labrador retriever who became the target of a nasty custody fight between a California couple after the dissolution of their domestic partnership. In the course of the lawsuit, one lawyer published two AI-fabricated citations in a filing. The opposing law firm didn’t catch the flaw and cited the same fake cases in its filings, including in a court order signed by a judge.
Most lawyers grew up in a time when you could expect the other side to spin and even to lie about the record some of the time, but just lying or making a mistake about the existence of a case was basically unheard of up until a few years ago.
— Eugene Volokh, UCLA law school
The case of Joan Pablo Torres Campos vs. Leslie Ann Munoz also points to how AI, touted worldwide as a labor-saving technology, has actually increased the workload in some trades and professions, like lawyering. For litigators, it has created a new imperative: ferreting out citations that have been fabricated by AI bots in their own court filings — and their adversaries’.
I’ve written before about the proliferation of AI-generated fabrications infiltrating legal filings and even legal rulings, despite the advice drilled into the heads of even law students about making sure that their citations to precedential cases are accurate. But the wave keeps building: A database of AI hallucinations maintained by the French researcher Damien Charlotin now numbers 1,174 cases, of which some 750 are from U.S. courts.
That’s almost certainly a conservative count. Most AI fabrications may not even come to the attention of litigants or judges, especially in state courts.
“For every case that talks about this, my guess is that there are many that aren’t visible,” says Eugene Volokh of UCLA law school and the Hoover Institution, who keeps a weather eye on AI-related courthouse developments. He believes there may be thousands escaping notice.
AI has introduced mistakes that were never seen in the past. “Most lawyers grew up in a time when you could expect the other side to spin and even to lie about the record some of the time, but just lying or making a mistake about the existence of a case was basically unheard of up until a few years ago,” Volokh told me. “That’s because there would be no source of hallucinations — maybe you’d get the citations slightly wrong or you mischaracterized or misquoted them, but to talk about a case that doesn’t exist — that didn’t happen. Now it happens a lot.”
The judiciary is getting increasingly nervous about AI fabrications becoming part of the judicial record. “Reliance on fake cases…seriously undermines the integrity of the outcome and erodes public confidence in our judicial system,” an appelate judge stated.
Therefore, he added, “it is imperative for both the court and the parties to verify that the citations in all orders are genuine….This is especially vital with the increasing incidence of hallucinated case citations generated by AI tools.”
Judges are still reluctant to bring down the hammer for AI-fabrications if lawyers acknowledge their fault and “throw themselves on the mercy of the court,” Volokh says. But they’re getting tougher on lawyers who deny their reliance on AI or try to shift blame.
As recently as Monday, federal Magistrate Mark D. Clarke of Medford, Ore., ordered the attorneys representing the plaintiff in a civil lawsuit to pay more than $90,000 in legal fees, on top of an earlier sanction of $15,500 imposed on one of the lawyers, for incorporating 15 fabricated case citations and eight misquotations into case filings.
Clarke also dismissed the $29-million lawsuit, which arose from a ferocious dispute among the sibling heirs to an Oregon winery fortune, with prejudice, so it can’t be refiled. It was an extraordinary punishment, Clarke acknowledged — and the largest penalty imposed in any case in Charlotin’s database.
“In the quickly expanding universe of cases involving sanctions for the misuse of artificial intelligence, this case is a notorious outlier in both degree and volume,” Clarke wrote. Among other faults, he noted, the plaintiff’s lawyers never adequately fessed up to their wrongdoing. “If there was ever an ‘appropriate case’ to grant terminating sanctions for the misuse of artificial intelligence,” he wrote, “this is it.”
That brings us back to the custody battle over Kyra. The case originated in 2024, two years after a family court judge in San Diego dissolved the domestic partnership of Joan Torres Campos and Munoz. The dissolution order allowed them to keep their own property, but didn’t mention the dog, who lived with Munoz.
Torres Campos subsequently sought shared custody of Kyra and visitation rights. (Pet custody battles have long been a cultural fixture: Film aficionados might recognize this case’s similarity to the custody fight over the wire-haired terrier Mr. Smith in the 1937 Cary Grant/Irene Dunne vehicle “The Awful Truth,” surely the funniest movie ever made by Hollywood.)
Munoz rejected Torres Campos’ request, arguing that he didn’t really care about the dog, but only aimed to harass her. A family court judge sided with her, but Torres Campos appealed.
In her initial reply to Torres Campos, Munoz’s lawyer, Roxanne Chung Bonar, cited California cases from 1984 and 1995 that she said supported her client’s refusal to grant visitation rights.
Both case citations were fictitious. The 1984 case, Marriage of Twigg, didn’t exist at all; Bonar’s citation pointed to a criminal case that had “nothing to do with pets or custody determinations,” California Appellate Judge Martin N. Buchanan wrote for a unanimous three-judge panel, upholding the family court judge . The second reference was to Marriage of Teegarden, which was handed down in 1986, not 1995, and also had nothing to do with the issue at hand.
Things only got more complicated from there. Torres Campos’ lawyer, in a reply brief and a subsequent proposed court order, didn’t mention that Twigg and Teegarden were fabricated cases, perhaps because the lawyer hadn’t checked the references personally. The family court judge signed the proposed order, including the fake citations, resulting on their infiltration into the official record. (Although Torres Campos’ lawyer drafted the proposed order, it actually rejected his lawsuit.)
It was only in the course of appealing the family court ruling did Torres Campos’ lawyer mention that the two cited precedents were “invented case law.”
There was one more turn of the screw: In responding to Torres Campos’ appellate filing, Bonar “doubled down,” Buchanan wrote. Bonar insisted that Twigg was a “valid, published precedent” and added three more purported citations to the case. All were “just as phony as the original citation,” Buchanan noted.
Bonar even taunted Torres Campos’ lawyer for his “failure to conduct basic legal research” to verify the ostensibly genuine precedents, adding that his “inability to locate them underscores the incompetence that led to his appeal’s dismissal.”
Where did these references come from? It turned out that the Twigg reference originally came from a Reddit article written by an Oregon blogger and animal rescuer who posts under the name “Sassafras Patterdale,” in which she cited the fictitious case in a post about pet custody battles. Munoz had received the article from a friend and passed it on to Bonar. Both of them assumed that everything in it was accurate.
According to the appellate ruling, the additional citations to Twigg don’t appear in the Reddit post. Bonar never explained where they came from. She did concede, however, that the fictitious citations “‘may have’ come from her use of AI tools,” Buchanan noted. He sanctioned her with a $5,000 fine, largely because she did not initially acknowledge that her citations were fake and tried to shift blame to her opposing counsel.
Although the appeals judges could have awarded the case to Torres Campos due to Bonar’s performance, they declined to do so — because Torres Campos’ lawyers hadn’t checked their opposing counsel’s citations themselves. At this stage, Munoz still has custody of the dog and the lawsuit is essentially over, according to Torres Campos’ attorney, David C. Beavens of San Diego.
Beavens says he took the case because he hoped to use it to obtain judicial clarification of a state law enacted in 2019, which authorized courts to issue orders regarding the ownership and care of pets in divorce cases. The appellate judges, sidetracked by the AI issue, never touched on that. But Beavens says he agreed with the panel’s position AI fabrications have become such a problem in court that “we need to hold everyone accountable” — lawyers on both sides of a case and the judges as well.
Bonar told me that she was not challenging the sanction but declined to comment on it further.
I did ask Bonar if she had any advice for other lawyers tempted to use AI in their work. “Yes,” she said: “Verify all third-party sources.”
Business
Commentary: It’s not just vaccines — from infancy to adolescence, Republicans are waging war on children’s health
The conservative assault on child health starts with the anti-vaccine campaign and proceeds to cutbacks in nutrition assistance and narrowed access to healthcare.
In the old days, before accepted medical protocols came under partisan assault, infants typically received a vitamin K shot to enhance blood-clotting capability and a few drops of an antibiotic to stave off eye infections before leaving the hospital, followed by a thorough round of vaccines against life-threatening diseases.
Americans assumed that “whatever a family could afford, the country had already decided this child was worth protecting,” Robert B. Shpiner, a critical care expert at UCLA medical school, wrote recently. “I have seen children harmed by disease, poverty, by bad luck. I had not, until now, seen them harmed so methodically by their own government.”
Shpiner’s targets were the changes in healthcare policies instituted by the Trump administration generally and Health and Human Services Secretary Robert F. Kennedy Jr., as well as the mistrust in medical authority that Kennedy and his followers have helped to foment.
We’re going to be paying this bill for years to come, because the lack of proper nutrition has profound effects on learning and disability.
— Robert B. Shpiner, UCLA
As Shpiner wrote in the Guardian, the administration’s assault on child health begins with its anti-vaccination policies. In January, Kennedy’s agency reduced the list of recommended childhood immunizations to 11 from 17, removing shots for COVID-19, hepatitis and meningitis, among other diseases. The agency made the changes without the customary professional consultations, KFF has reported.
But that’s only the tip of the iceberg. “It’s just one thing after another,” Shpiner told me.
What triggered him into writing his Guardian essay, he says, was learning that congressional Republicans had advanced an agriculture appropriations bill that would cut the fruit and vegetable benefit for children in WIC, the supplemental nutritional program for women, infants and children to $10 a month from $26.
“That got me to looking at this as a sequence,” he says, starting with the reduction of child immunizations, followed by the proposed cuts in WIC and the cuts in food stamps enacted as part of the Republican budget bill that Trump signed one year ago Saturday (i.e., the Fourth of July, 2025).
“The image of us taking food away from kids and not giving them enough money to buy some apples and berries—the short-term response is outrage,” he says, “but the medium- and long-term effect is that we’re going to be paying this bill for years to come, because the lack of proper nutrition has profound effects on learning, and disability and anemia. A number of measures of health and success match with nutrition.”
At almost every stage of childhood development, he notes, programs aimed at preserving or enhancing children’s health have gone on the chopping block.
“A vaccine rule one week, a food program the next,” he wrote. “Each change arrives wrapped in a reasonable rationale: fiscal discipline, local control, parental choice. But arrange them in the order a child actually grows, and the rationales stop mattering.”
Judging from their rhetoric, one would think that Republicans would move heaven and earth to foster child immunizations, nutritional assistance and access to medical care.
In “Communion,” his recent book about his conversion to Catholicism, for example, Vice President JD Vance writes: “We want more children in our society because children are profoundly good — the greatest value add we can create.”
Yet the programmatic cutbacks advocated for and implemented by the Republican Congress and Trump give the lie to that sentiment. Let’s examine chapter and verse.
Measles is the canary in the coal mine for vaccination and public health, and at this moment, the canary is singing a doleful tune. The Centers for Disease Control and Prevention count 2,134 cases in the U.S. as of June 25. That’s poised to exceed the 2,288 cases in all of 2025, which was the worst outbreak since 1991.
There’s no question why this is happening. It’s because of a decline in measles vaccinations below the 95% generally considered to provide “herd immunity,” in which the disease is so rare that even unvaccinated individuals are protected from exposure.
Kennedy may not deserve all the blame for the immunization decline, but as pseudoscience debunker Steven Novella has pointed out, as secretary he has “done everything possible to undermine vaccine science and confidence in health institutions.”
Kennedy has paid lip service to the value of the MMR vaccine, which combines immunizations for measles, mumps and rubella. But he has claimed without evidence that the vaccine causes deaths “every year” and that the vaccine hasn’t been safety-tested, which isn’t so. He has asserted that it shouldn’t be subject to a government mandate. He also has promoted treatments for measles that aren’t known to be effective.
(The Department of Health and Human Services didn’t respond to my request for comment on the vaccine initiatives.)
As children grow, the crisis of malnutrition kicks in. The House GOP’s cuts to WIC are still only on the drawing board. But the Republican budget bill incorporated cuts to food stamps — the Supplemental Nutrition Assistance Program, or SNAP — that have driven some 4 million people off the program. In 13 states that have published data, according to the Center on Budget and Policy Priorities, child enrollment fell by more than 800,000, or 16%, between July 2025 and May of this year.
“This is where the nutrition cuts become a medical, not merely a moral, story,” Shpiner says. “Iron-deficiency anemia in infancy is associated with poorer cognitive, motor, and behavioral outcomes that persist more than 10 years after the deficiency itself has been corrected — the deficit does not fully reverse even with later treatment. Withdrawing produce and protein from WIC and SNAP at the peak window of brain growth is not a budget line that resets the following year; it is a developmental exposure with a long tail.”
The combination of reduced immunization and poor nutrition build on each other. “Unvaccinated kids are going to get sicker,” he told me. “If they’re malnourished, they’re going to get sicker. If their parents don’t get affordable care, they’re going to be strapped. It becomes a synergistic and multiplicative cascade.”
Indeed, the administration’s assault on Medicaid and the Affordable Care Act intensifies the damage. Enrollment in Medicaid and the Children’s Health Insurance Program, which is part of Medicaid, fell by 4.8 million people, or 6%, from March 2025 through March 2026, according to government data. The enrollment decline for children alone came to more than 1.9 million, or 5%.
White House spokesperson Kush Desai challenged the latter figure when I asked for comment. But it came from KFF, which sourced it to the government’s Centers for Medicare and Medicaid Services, or CMS.
“Nothing has been done to alter insurance or Medicaid coverage of any vaccination,” Desai told me by email, “and parents are encouraged to seek out the counsel of their pediatrician to make the best decisions for their children.”
The prospects are for further declines. That’s because new work requirements for enrollees in Medicaid expansion under the Affordable Care Act are almost certain to drive enrollment down, due to obstacles including paperwork burdens and administrative snafus, resulting in even some eligible enrollees losing their coverage.
(These problems became so pronounced in Arkansas, which implemented work requirements during the first Trump term, that a federal judge axed the program.)
The work rules enacted last year as part of the Republican budget bill aren’t scheduled to start until Jan. 1, but three states are starting early — Nebraska (May 1), Montana (Wednesday) and Iowa (Dec. 1). The impact on enrollment isn’t yet clear.
Whatever the effect of these changes, the public is going to know less about them than before. The reason is that the administration has shrunk the requirements for reports of immunization from states, changing the reports from mandated to voluntary. The affected data include childhood immunization rates against diphtheria, tetanus, pertussis, polio, measles, mumps and rubella, hepatitis, chicken pox and flu; and rates for 13 year olds and expectant mothers.
“While seemingly a small, technical change, the removal of vaccine reporting in Medicaid and CHIP may make it more difficult to monitor and understand vaccination trends for a large share of children in the U.S.,” KFF noted.
I asked the Department of Health and Human Services to explain the rationale for these changes, and specifically whether they were aimed at obscuring the effect of the narrowing of vaccine recommendations, but didn’t hear back.
Business
How the FIFA World Cup is providing a boost for L.A. businesses
Johnny Beig may have played in a semi professional cricket league in Australia, but this summer he’s a big fan of soccer in the United States.
It’s not just because he’s rooting for the World Cup team, though.
FIFA emblems are featured on jerseys that were created by the Dioz Group and distributed for all employees at the 16 FIFA World Cup venues this summer.
(Genaro Molina / Los Angeles Times)
Last year, Beig’s Beverly Hills-based company, Dioz Group, won a $2.5 million contract with On Location, FIFA’s hospitality partner, to design, manufacture and distribute uniforms for all employees working at FIFA World Cup venues this summer.
These include the people welcoming attendees into stadiums, VIP lounge chefs, waiters and the flagbearers during the opening ceremony.
After a multi-step application process, including presentations of its planning and strategy, Dioz says it produced more than 50,000 clothing garments including suits, jackets, shirts and hats and delivered them to the 16 World Cup venues around the U.S., Canada and Mexico in June.
Thanks in part to the World Cup contract, the company’s revenue has reached $15 million so far this year, compared with $20 million last year, Beig said. He declined to disclose the company’s net income but said the business was profitable.
“We are working with larger names that we would have never imagined we would,” he said. “The FIFA World Cup is the pinnacle. Working with the largest sporting event in the world is what we’re very proud of. I don’t think it gets any bigger than that.”
Volunteers line up to prepare to display the Canadian flag before a World Cup round of 32 knock-out match between Canada and South Africa at SoFi Stadium on Sunday.
(Kelvin Kuo / Los Angeles Times)
Dioz is among the many small businesses across Los Angeles that are getting a boost from the global sporting event, said Kevin Klowden, a senior fellow at the Milken Institute.
The influx of hundreds of thousands of fans into the city has been a boon to hotels, transportation services and restaurants, in addition to those in the special events and logistics economy, Klowden said, calling the event the “equivalent of multiple Super Bowls.”
“The number of contracts that are there, it’s a big deal,” he said. “Given the fact that L.A.’s filming is only slowly recovering, having something like the World Cup is definitely a boost.”
Dioz was co-founded by Johnny, 44, and his brother Tony in 2006. The brothers were born in India and raised in Australia, where Johnny enjoyed a brief career as a semi professional cricket player.
He realized his future wasn’t as a professional athlete, but he wanted to stay connected to the sports world, so he began making uniforms for his cricket team in 2006.
He then got a referral to make uniforms for multiple teams in the area before starting an apparel company.
“I wanted to stick with something I was passionate about, which is sports,” he said.
Volunteers unravel the center field display before a World Cup round of 32 knock-out match between Canada and South Africa at SoFi Stadium on Sunday.
(Ronaldo Bolanos / Los Angeles Times)
In 2012, Beig moved to Los Angeles and established Dioz‘s Los Angeles headquarters to tap into the U.S. market. During the pandemic, the company started supplying medical apparel to hospitals and schools, and the business took off, with revenue doubling in 2020, Beig said.
Dioz now has over 150 employees, including 15 in L.A., and manufactures its apparel at factories in China, India, Bangladesh, Turkey and the Philippines. Tony runs an office in Dubai.
Before the World Cup, Dioz provided employee uniforms for events including Super Bowl LIX and Copa America, which may have given it a leg up on the FIFA contact.
Now, with a World Cup contract on their resume, Beig said he’s setting his sights on even bigger events.
“This gives us an edge over the next FIFA events worldwide as well, where we can showcase our skills and we can handle it,” Beig said. “So it gives us a good opportunity to work with sporting events like the UEFA Championship and Premier League.”
As companies get new business from the World Cup, Klowden said it’s important that they leverage their new position to continue that growth.
Companies that benefited from the World Cup might be in a position to bid on even bigger contracts, especially with the Olympics coming up in 2028, Klowden said.
“The really important part in any of these deals is that if a company ran something like this, then they are able to build off of that success,” Klowden said. “Let’s say you’re a company that did a big uniform order or a big food order, and the World Cup goes, and you invested in new manufacturing capacity, or you invested in new clothing machines, or whatever you do; suddenly you don’t have that market anymore, then you’ve just wasted all that money ramping up.”
Business
Home insurer surcharges for wildfires is legal, judge rules
Surcharges that California homeowners have been hit with statewide by insurers defraying the costs of Los Angeles County’s wildfires were ruled legal in a decision released late Tuesday.
L.A. County Superior Court Judge Tiana Murillo turned down a petition by advocacy group Consumer Watchdog to halt the charges, which insurers began levying last year after the state’s insurer of last resort couldn’t pay all its January 2025 fire claims.
The California FAIR Plan, financially backed and operated by the state’s licensed home insurers, needed a $1-billion bailout from the insurers after it was hit with some $4 billion in claims.
Under a deal Insurance Commissioner Ricardo Lara worked out with the FAIR Plan in 2024, the insurers could seek state approval to surcharge their residential policyholders for up to half of any assessment totaling $1 billion in case the plan needed a bailout in an “extreme worst case scenario” — as it turned out it did.
A total of 105 insurers, including State Farm General — California’s largest home insurer — Farmers and Mercury sought and received approval for the surcharges.
Because the FAIR Plan assessed its member insurers based on their share of the state’s home insurance market, the policyholder surcharges were in the same ballpark. The median fee for homeowners was $28, according to the department of insurance.
The fee can be more or less according to the size of a homeowner’s premium and is split into monthly payments that insurers can spread over one or two years. Condo owners and renters on average were surcharged less.
In a court filing, Consumer Watchdog said $420 million in surcharges were approved.
In its April 2025 lawsuit filed against Lara, the Los Angeles group made a series of arguments in seeking to overturn the residential surcharges, which it deemed an industry bailout. It did not sue over related commercial surcharges.
Consumer Watchdog contended in its lawsuit that the surcharges violated Proposition 103 — the 1988 measure that governs insurer rate hikes — because the proposition does not allow for them.
It also claimed Lara did not follow regulatory protocol in promulgating the new policy.
The group further alleged that the FAIR Plan’s governing statutes do not give Lara the authority to permit the surcharges — and that the statutes require insurers to share in the plan’s profits and losses, and not shift losses to policyholders.
Murillo, and another judge who previously heard the case, turned down all of the consumer group’s arguments in separate rulings, the last of which Murillo issued Tuesday night.
Lara celebrated his legal victory over Consumer Watchdog, which has accused Lara of having close ties to insurers and sought to oust him from office. His terms ends in January.
“This victory sends a loud and clear message: The era of allowing special interests to derail consumer choice is over. We have the momentum, we have the authority, and we will continue to fight until every Californian has access to the coverage they deserve,” Lara said in a statement.
Attorney Will Pletcher, litigation director of Consumer Watchdog, said the group disagreed with the decision and would “consider all options to move this forward.”
“It’s important to try to protect California consumers from these surcharges that we think are in pretty clear conflict with both Proposition 103 and the FAIR Plan,” he said.
Hilary McLean, a spokesperson for the plan, said in a statement it did not have any position on the ruling, given the plan “does not have a role in determining how insurers manage costs associated with assessment.”
Denni Ritter, vice president of state government relations for the American Property Casualty Insurance Assn., a major industry trade group, said the decision rejected “the reckless lawsuit brought by the self-interested group Consumer Watchdog…”
“This ruling preserves a vital tool to protect the stability of the California insurance market. Blocking cost recovery would have undermined the state’s last-resort coverage option,” she said in a statement.
The 2024 policy was issued in response to the rapid growth of the plan due to a series of wildfires over the last decade that prompted multiple insurers to retreat from the state’s home insurance market.
The plan had 264,000 homeowners on its rolls in September 2022, a figure that rose to 452,0000 in the months before the fires — and its residential policyholders have since increased to 663,000 as of March.
The FAIR Plan offers policies that typically cost more than those issued by regular insurers while offering less coverage.
A Times analysis last year found that in the Palisades and Eaton fire zones, the plan’s rolls nearly doubled to 28,440 from 2020 to 2024.
That concentration of policyholders led to the plan’s large losses during the Jan. 7 wildfires, which damaged or destroyed more than 18,000 structures, killing at least 31 people.
It’s been estimated that the insured losses for the wildfires could ultimately total as much as $40 billion, exceeding any past wildfires worldwide. Ritter said that so far insurers have paid $23.7 billion in claims.
The 2025 wildfires were not the only time the FAIR Plan has needed a bailout, though it is the first time its member insurers surcharged policyholders.
In 1993, it assessed carriers after fires in Altadena and Malibu, and in 1994 it did so after the Northridge earthquake. The assessments totaled $260 million.
The plan received approval this year from the insurance department for a 29% rate increase for its homeowner dwelling policy that will take effect in October.
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