CommNV, LLC v. Uprise, LLC
Second Judicial District Court of the State of Nevada, Washoe County · Nev. 2d Jud. Dist. Ct. (Washoe County) · Nevada bar guidance
Verified April 26, 2026
- Citation
- CommNV, LLC v. Uprise, LLC, No. CV23-02123 (Nev. 2d Jud. Dist. Ct., Washoe Cnty. Sept. 5, 2025)
- Decided
- September 5, 2025
Summary
Attorneys Jan Tomasik and Daniel Mann of Cozen O'Connor filed a brief containing fourteen fictitious citations generated by ChatGPT. Judge David Hardy ordered the attorneys removed from the case, referred them to the Nevada State Bar for discipline, and imposed monetary sanctions of $2,500 per attorney ($5,000 total) payable to legal aid. Judge Hardy then suspended the monetary and removal sanctions on condition that the attorneys complete an alternative remediation program he framed as "reintegrative shame."
- AI tool:
- ChatGPT
- Sanction amount:
- $5,000
What sanction did the court impose?
$5,000 in monetary sanctions ($2,500 per attorney) plus removal from the case and Nevada State Bar referral, all suspended on condition that within sixty days the attorneys notify Nevada State Bar leadership of the misconduct, serve on or mentor an AI policy committee, volunteer to speak at continuing legal education programs, write a legal publication article detailing lessons learned, inform law school deans of their conduct, and offer to guest lecture in legal ethics courses on AI use.
Why does CommNV, LLC v. Uprise, LLC matter for law firms using AI?
CommNV v. Uprise is notable less for the dollar figure than for the remediation framework Judge Hardy substituted for traditional discipline. Managing partners reviewing AI policy should treat the suspended-sanctions structure as a signal that Nevada trial judges may pair monetary penalties with mandatory teaching and bar-engagement obligations, lengthening the real-world cost of a fabricated citation well beyond the headline fine.
Sources
Further reading
- https://www.lawnext.com/2025/09/nevada-judge-takes-creative-and-unusual-approach-to-combat-ai-generated-fictitious-citations.html
- https://mynews4.com/news/local/judge-pauses-uprise-lawsuit-questions-ai-use-by-attorneys
- https://www.youtube.com/watch?v=zVni1Bxo6kI
- The full text of Judge Hardy's signed sanctions order has not been retrieved from a primary court source. Facts above are reconstructed from contemporaneous press coverage of the September 5, 2025 hearing and from the Washoe County docket entry for case CV23-02123. The exact count of fictitious citations (14) and the precise sixty-day compliance window should be confirmed against the order itself before republication.