Valley Health System, LLC v. Estate of Jane DoeAnnotate this Case
The Supreme Court affirmed the order of the district court sanctioning a party for discovery violations and finding that the party’s attorneys violated Nevada Rule of Professional Conduct (RPC) 3.3(a)(1) by making a false statement of fact or law to the court, holding that the district court acted within its discretion when it sanctioned the party for violating Nev. R. Civ. P. 16.1.
The Court further concluded that a district court’s citation to the RPC in support of a determination of attorney misconduct causes reputational harm that amounts to a sanction and that the district court correctly determined that the attorneys violated RPC 3.3(a)(1). Lastly, although the attorneys were not provided sufficient notice that their conduct was under review, any notice deficiencies were subsequently cured by the attorneys’ motion for reconsideration.