District courts must apply the catalyst theory to determine whether a party prevails in litigation related to public records. A district court abuses its discretion when it fails to consider all five factors under Las Vegas Metropolitan Police Department v. Center for Investigative Reporting, Inc., 136 Nev. 122, 460 P.3d 952 (2020) (“CIR” factors). Courts must make proper findings for each of the five factors and balance the factors to determine whether a party prevailed.
McCormick-Huhn, Kaitlin, "Las Vegas Review-Journal v. City of Henderson, 137 Nev. Adv. Op. (Dec. 23, 2021)" (2021). Nevada Supreme Court Summaries. 1473.