CommNV v. Uprise

CommNV, LLC v. Uprise, LLC, Second Judicial District Court of Nevada, Washoe County, September 10, 2025, No. CV23-02123 (order imposing and suspending sanctions). Judge David A. Hardy. Primary document held (Order Imposing and Suspending Sanctions, e-filed September 10, 2025; retrieved from the signed order linked in the Reuters article below and added to the held set at the full pass's Stage 2; this entry was originally supported by the secondary sources below per the backfill instructions). Sources: https://www.tradingview.com/news/reuters.com,2025:newsml_L2N3UY0WN:0-some-judges-move-beyond-fines-to-keep-lawyers-ai-errors-in-check/ (Reuters); https://www.lawnext.com/2025/09/nevada-judge-takes-creative-and-unusual-approach-to-combat-ai-generated-fictitious-citations.html; https://clarkcountybar.org/scitech-law-beyond-artificial-intelligence-the-real-question-can-nevada-lawyers-afford-to-ignore-scitech/ (Nevada bar article citing the September 10, 2025 order).

Attorneys Daniel Mann and Jan Tomasik of Cozen O'Connor (identified in secondary coverage as Daniel A. Mann and Jan K. Tomasik; the sanctions order gives no middle initials) filed a brief containing at least fourteen fictitious case citations generated by ChatGPT, plus misquoted and misrepresented authorities. Associate Mann used ChatGPT to help draft and edit the document and accidentally filed an early, uncorrected draft; Tomasik, the lead attorney, signed off without knowing Mann had used ChatGPT. The firm apologized and stated it has a strict policy barring public AI tools for client work; it terminated Mann.

The court imposed traditional sanctions on both lawyers: removal from the underlying lawsuit, referral to the Nevada State Bar for discipline, and a $2,500 fine each to be donated to legal aid. It then immediately suspended those sanctions in favor of a remedial alternative: within sixty days, each lawyer was to send letters to the Nevada State Bar president and vice president and to the deans of their law schools explaining their conduct, make themselves available to an AI-policy committee, and volunteer to speak at continuing education classes on AI and professional conduct.

Never file a draft without a final verification pass; an early, uncorrected draft should never reach the court. Supervising and signing attorneys must confirm how research was produced before putting their names on a brief, since firm AI policies only work if enforced at sign-off.

• Sources: https://www.tradingview.com/news/reuters.com,2025:newsml_L2N3UY0WN:0-some-judges-move-beyond-fines-to-keep-lawyers-ai-errors-in-check/
• lawnext.com: https://www.lawnext.com/2025/09/nevada-judge-takes-creative-and-unusual-approach-to-combat-ai-generated-fictitious-citations.html
• clarkcountybar.org: https://clarkcountybar.org/scitech-law-beyond-artificial-intelligence-the-real-question-can-nevada-lawyers-afford-to-ignore-scitech/