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.

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.”

Singer-songwriter FKA twigs is suing her ex-boyfriend, actor Shia LaBeouf, claiming that he is trying to “silence” her from speaking out against sexual abuse through the use of an “unlawful” nondisclosure agreement.

The complaint, filed in Los Angeles Superior Court on Wednesday, seeks a court order to prohibit LeBeouf from enforcing sections of an NDA which Tahliah Barnett — the Grammy Award-winning singer’s legal name — says violates California law.

“Shia LaBeouf has tried to control Tahliah Barnett for the better part of a decade,” the filing states.

“This action was taken in response to Mr. LaBeouf’s attempt to bully and intimidate twigs through a frivolous and unlawful secret arbitration he filed against her in December in which he sought to extract money from her,” said the singer’s attorney Mathew Rosengart, national co-chair of media & entertainment litigation at Greenberg Traurig in Century City, in a statement.

Rosengart added that twigs “refuses to be bullied anymore. She is instead standing up for herself and other survivors of sexual abuse who have improperly been silenced. This is the unusual case that is not about money but about justice and upholding and enforcing California law and policy designed to protect survivors by nullifying illegal NDAs.”

LaBeouf’s attorney Shawn Holley of Kinsella Holley Iser Kump Steinsapir denied the claims.

“When Ms. Barnett and Mr. LaBeouf both decided to resolve their differences and move on with their lives, no one forced her or ‘bullied’ her to stay silent,” Holley said in a statement.
“As a woman with agency, she decided to settle the case and accepted money to dismiss her lawsuit.”

The suit arises out of litigation that Barnett brought against LaBeouf in 2020, when she accused the actor of “physical, sexual, and mental abuse” during their relationship,” as well as “knowingly infect[ing]” Barnett with a sexually transmitted disease.” That case was settled last year.

In a response to the suit, the actor told the New York Times that “many of these allegations are not true.”

But he added, “I am not in the position to defend any of my actions. I owe these women the opportunity to air their statements publicly and accept accountability for those things I have done.”

In the statement Thursday, Holley added that the claim of sexual battery “was disputed, as were the other claims made in Ms. Barnett’s lawsuit.”

According to the new lawsuit, LaBeouf filed a secret arbitration complaint and “improperly sought exorbitant monies” from Barnett last December, claiming she had breached their agreement by violating its nondisclosure provisions after she gave an interview to the Hollywood Reporter in October.

In the interview, Barnett was asked if she felt safe and answered that as a woman of color in the entertainment industry, she “wouldn’t feel safe” and discussed her involvement with organizations that support survivors, saying, “I think it’s less about me at this point and more about looking forward. Just, you know, moving on with my life.”

The agreement Barnett reached with LaBeouf “contained a deficient and unlawful NDA that is unenforceable,” under California’s Stand Together Against Non-Disclosure Act, according to the complaint. The law forbids NDAs from being used to silence victims of sexual misconduct.

“As the California Legislature has made clear, survivors should have the right to tell their stories without fear or coercion, and California law does not and must not allow abusers and bullies to silence them through secret agreements containing unconscionable, unlawful gag orders,” the complaint states.

The lawsuit further alleges that while LaBeouf has sought to prohibit Barnett from talking about her abuse, he has “repeatedly brought up his relationship with Ms. Barnett—on his own and without being directly asked about her—materially breaching the very confidentiality provisions that he had just contended were fully enforceable against Ms. Barnett.”

While the actor agreed to drop the arbitration in February, he has “refused to acknowledge, however, that the NDA provisions are illegal and unenforceable,” the filing states.

The latest round in LaBeouf’s legal battle with Barnett comes just weeks after a New Orleans judge ordered the actor to begin substance abuse treatment and undergo weekly drug testing after he was arrested on suspicion of assaulting two men in the city’s French Quarter. LaBeouf was also required to post $100,000 bond as part of the conditions of his release. He was charged with two counts of simple battery, the Associated Press reported.

Warner Bros. Discovery shareholders will soon render a verdict on Hollywood’s biggest merger in nearly a decade.

Warner has set an April 23 special meeting of stockholders to vote on the company’s proposed sale, for $31-a-share, to the Larry Ellison family’s Paramount Skydance.

The $111-billion deal is expected to reshape the entertainment industry by combining two historic film studios, dozens of prominent TV networks, including CBS, HBO, HGTV and Comedy Central, streaming services and two news organizations, CNN and CBS News. The tie-up would give Paramount such beloved characters as Batman, Wile E. Coyote, and Harry Potter, television shows including “Hacks,” and “The Pitt,” and a rich vault of movies that includes “Casablanca,” and “One Battle After Another.”

The $31-a-share offer represents a 63% increase over Paramount Chairman David Ellison’s initial $19-a-share proposal for the company in mid-September, and a 147% premium over Warner’s stock’s trading levels prior to news of Ellison’s interest.

“This transaction is the culmination of the Board’s robust process to unlock the full value of our world-class portfolio,” Warner Bros. Discovery Chief Executive David Zaslav said Thursday in a statement. “We are working closely with Paramount to close the transaction and deliver its benefits to all stakeholders.”

Paramount hopes to finalize the takeover by September. It has been working to secure the blessing of government regulators in the U.S. and abroad.

Should those regulatory deliberations stretch beyond September, Paramount will pay shareholders a so-called “ticking fee” — an extra 25 cents a share for every 90-day-period until the deal closes.

The transaction will leave the combined company with nearly $80-billion in debt, a sum that experts say will lead to significant cost cuts.

For weeks it appeared that Netflix would scoop up Warner Bros.

Netflix initially won the bidding war in early December with a $27.75 offer for the studios and streaming services, including HBO Max. But Ellison refused to throw in the towel. He and his team continued to lobby shareholders, politicians and Warner board members, insisting their deal for the entire company, including the cable channels, was superior and they had a more certain path to win regulatory approval.

The Ellison family is close to President Trump. This week, Trump named Larry Ellison to a proposed White House council on technology issues, including artificial intelligence.

Warner’s board, under pressure, reopened the bidding in late February to allow Paramount to make its case. Warner board members ultimately concluded that Paramount’s bid topped the one from Netflix and the streamer bowed out. Paramount paid a $2.8-billion termination fee to Netflix and signed the merger agreement on Feb. 27.

Warner’s board is advising its shareholders to approve the Paramount deal. Failure to cast a vote will be the same as a no-vote, according to the company’s proxy.

Warner’s largest shareholders include the Vanguard Group, BlackRock, Inc. and State Street Corp.

Zaslav has significant stock and options holdings, worth about $517 million at the deal’s close, according to the proxy.

The regulatory filing also disclosed that a mysterious bidder had surfaced at the auction’s 11th hour.

A firm called Nobelis Capital, Pte., reportedly based in Singapore, alerted Warner on Feb. 18 that it was willing to pay $32.50 a share in cash.

The firm said it had placed $7.5 billion into an escrow account. However, Warner’s bankers “could not find the purported deposit at J.P. Morgan,” according to the proxy. And there was no evidence that Nobelis had any assets or any “equity or debt financing” lined up, Warner said, adding that it “took no further action with respect to the Nobelis proposal.”