Schaaf v. Nellis Auction Holdings, LLC
U.S. District Court, District of Nevada · D. Nev. · Nevada bar guidance
Verified April 26, 2026
- Citation
- Schaaf v. Nellis Auction Holdings, LLC, No. 2:25-cv-00647-JCM-NJK, 2026 WL 266231 (D. Nev. Jan. 30, 2026) (Koppe, M.J.)
- Decided
- January 30, 2026
Summary
Plaintiff's counsel Jason Kuller (Rafii & Associates, P.C.) filed three briefs containing improper citations to caselaw stemming from over-reliance on artificial intelligence. Defendants moved for case-terminating sanctions, to strike the offending briefs, and to stay the case. Magistrate Judge Nancy J. Koppe denied all three motions but admonished Kuller for his lapse in his duties as an officer of the Court, noting that the bad citations appeared in motion briefing rather than in a pleading and that defendants had already addressed the errors in the underlying briefing itself. The order also flagged separate problematic conduct by Kuller, including a missed opposition deadline after multiple extensions, exceeding the scope of court-ordered supplemental briefing, and ad hominem attacks on opposing counsel.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Formal admonishment of Plaintiff's counsel Jason Kuller; no monetary sanction and no case-dispositive sanction imposed. The court warned that continued conduct of this kind would result in serious sanctions, up to and including case-dispositive sanctions on his clients, monetary sanctions, and referral to the state bar.
Why does Schaaf v. Nellis Auction Holdings, LLC matter for law firms using AI?
Schaaf is a useful counterpoint for managing partners watching the AI-sanctions docket. The court declined to impose monetary or case-terminating sanctions, but only because the fabricated citations appeared in motion briefing that opposing counsel had already rebutted, rather than in a pleading whose factual allegations a court must accept as true. The admonishment is on the public record under counsel’s name, with an explicit warning that a repeat will draw monetary sanctions, dismissal of his clients’ claims, and a state bar referral. For a small firm, the lesson is that even a no-dollar outcome is a reputational event that surfaces on every future Westlaw search of the lawyer’s name.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.
- CourtListener docket URL inferred from case caption and docket number; not directly retrieved during verification. The Charlotin-hosted Westlaw reprint (2026 WL 266231) is the verified primary-equivalent source.
- The order does not name the specific generative AI tool used by counsel.