uld have justifiably invoked the doctrine to dismiss a complaint seeking recovery for conversion of “five highlighters, an extension cord, four [small] wooden picture frames, a stainless steel pen and pencil set, a mirror, three hospital bracelets, and a fan”); Manufacturers Supply Co. v. Mullins , 167 A.2d 755, 756-57 (R.I. 1961) (invoking the doctrine where an owner was briefly deprived of his car while it was detained in a garage). See generally 1 Am. Jur. 2d Actions § 51 (2005). [36] We recognize that in extreme circumstances, transmitting unauthorized facsimile advertisements may constitute conversion. But here, the transmission of a single, one-page facsimile does not constitute extreme circumstances. [37] See Lied v. County of Clark , 94 Nev. 275, 278, 579 P.2d 171, 173 (1978). [38] On appeal Edwards neglected to address in his briefs or in his memoranda of supplemental authority the district court’s dismissal of his claims that Cenicola-Helvin’s conduct violated NRS 40.140(1), 41.600, 598.0918(3), 598.0923(3), and 598.073 and constituted intrusion. In this way, Edwards neglected his responsibility to cogently argue, and present relevant authority, in support of his appellate concerns. Thus, we need not consider these claims. See Weaver v. State, Dep’t of Motor Vehicles , 121 Nev. ___, 117 P.3d 193, 198-99 (2005); Maresca v. State , 103 Nev. 669, 673, 748 P.2d 3, 6 (1987); City of Las Vegas v. Bailey , 92 Nev. 756, 558 P.2d 622 (1976); Ellison v. State , 87 Nev. 4, 4 n.1, 479 P.2d 461, 461 n.1 (1971); NRAP 28(a)(4). [39] Bd. of Gallery of History v. Datecs Corp. , 116 Nev. 286, 288, 994 P.2d 1149, 1150 (2000) (recognizing that the district court may award attorney fees when authorized by a statute, rule, or contractual provision). [40] Kahn v. Morse & Mowbray , 121 Nev. ___, ___, 117 P.3d 227, 238 (2005) (quoting County of Clark v. Blanchard Constr. Co. , 98 Nev. 488, 492, 653 P.2d 1217, 1220 (1982)); see also Bergmann v. Boyce , 109 Nev. 670, 676, 856 P.2d 560, 564 (1993) (noting that NRCP 11 sanctions are reviewed under an abuse of discretion standard). [41] See NRS 18.010(2)(b); NRCP 11. ***************************** 122 Nev. Adv. Op. No. 16 February 23, 2006 IN THE SUPREME COURT OF THE STATE OF NEVADA No. 39292 LANE SIMONIAN, Appellant, vs. THE UNIVERSITY AND COMMUNITY COLLEGE SYSTEM OF NEVADA, Respondent. Proper person appeal from a district court order granting summary judgment and awarding attorney fees as sanctions in a false claims action. Second Judicial District Court, Washoe County; James W. Hardesty, Judge. Affirmed in part and reversed in part. Lane Simonian, Reno, in Proper Person. Mary Phelps Dugan, Associate General Counsel, Reno, for Respondent. BEFORE ROSE, C.J., DOUGLAS and PARRAGUIRRE, JJ. OPINION PER CURIAM: In this proper person appeal, we determine whether the district court properly granted summary judgment to the University and Community College System of Nevada (UCCSN) because, as a state entity, UCCSN is not subject to liability under Nevada’s False Claims Act (FCA).[1] We also consider whether sanctions may be imposed on a complainant for having filed an FCA action based on allegations that, in the context of an administrative retaliation proceeding, were previously found meritless. We agree with the district court that UCCSN is a state entity and therefore not subject to FCA liability. Accordingly, we affirm the district court’s summary judgment. We further conclude, however, that the district court’s award of attorney fees as a sanction for having asserted a meritless claim is unsupportable under the circumstances. Thus, we reverse the portion of the order awarding UCCSN attorney fees. FACTS Appellant Lane Simonian was a part-time instructor for Truckee Meadows Community College for several years. As a result of concerns that surfaced during his employment, Simonian instituted proceedings against respondent UCCSN on four notable occasions. First, in 1999, Simonian filed a district court petition for extraordinary relief, challenging UCCSN’s alleged refusal to pay part-time instructors the entire salary amounts for which legislative appropriations had been made. Within a few months of petitioning the court and before any response had been filed, however, Simonian voluntarily dismissed the petition. Second, that same year, Simonian requested a hearing with the Nevada Department of Personnel under NRS 281.641, which governs reprisals and retaliatory actions taken against state officer or employee whistleblowers.[2] In his request, Simonian asserted that he had sent letters to certain individuals and agencies, alleging that UCCSN had misappropriated state funds by submitting incorrect part-time instructor salaries in budget requests to the Legislature. Consequently, Simonian claimed, the community college retaliated against him by refusing to renew his teaching contract. After reviewing the matter, a hearing officer found that Simonian had not proven his retaliation claim, in part because Simonian had not demonstrated success on the merits of his underlying misappropriation allegations, and without so doing, he could not succeed on a claim for retaliation. Third, the following year, Simonian filed a second NRS 281.641 request, this time alleging that he had been retaliated against when he was dismissed as a part-time lecturer earlier that year. Simonian claimed that the dismissal resulted from his public complaints about “the false reporting of average new full-time instructors’ salaries.” The request was dismissed as untimely. Finally, in 2001, Simonian instituted a false claims action against UCCSN. As a basis for relief, Simonian asserted that between 1987 and 2001, UCCSN had “presented to the Nevada State Legislature claims for $16 million in unpaid salaries for part-time instructors.” He requested that UCCSN be assessed treble damages, a civil penalty payable to the State, and $5,000 for his expenses, plus costs. The Attorney General, although statutorily permitted to intervene in the action, declined to do so. The district court granted UCCSN’s ensuing motion to dismiss, treating it as a motion for summary judgment, and UCCSN’s request for attorney fees as sanctions under NRCP 11 and NRS 357.180(2). Specifically, the district court determined that Simonian had failed to state an FCA claim because a legislative budget request does not fall within the FCA’s definition of “claim” and because UCCSN is not a “person” for purposes of FCA liability. In addition, the district court summarily determined that Simonian’s claim was barred by the doctrine of collateral estoppel. Finally, the district court noted that Simonian had previously brought actions against UCCSN on the issue of part-time UCCSN instructor salaries and awarded UCCSN $2,452.50 in attorney fees, as sanctions against Simonian for presenting “a claim . . . not well-grounded in fact or in existing law.” Simonian appeals from the district court’s order. DISCUSSION This court reviews orders granting summary judgment de novo.[3] Summary judgment is appropriate when, after an examination of the record viewed in a light most favorable to the nonmoving party, no genuine issues of material fact remain and the moving party is entitled to judgment as a matter of law.[4] As, legally, state entities are not subject to FCA liability and no material factual disputes exist as to UCCSN’s state entity status, we conclude that the district court properly granted summary judgment on that basis. Consequently, we do not reach Simonian’s arguments regarding the district court’s alternative bases for summary judgment, that an entity’s budget request does not constitute a “claim” for FCA purposes and that the action was barred under the collateral estoppel doctrine. State entities are not “persons” subject to FCA liab

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