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• Had a role in the 2018 Nike extortion scheme
• Aided and abetted Avenatti, knowingly assisting wrongful conduct
• Breached his duties as a lawyer

Crucially, the jury stopped short of finding that Geragos defrauded or actively concealed information from Franklin, and concluded that Franklin suffered no direct harm from Geragos. But the recent finding that Geragos aided and abetted Avenatti in the extortion scheme, and knowingly assisted in wrongful conduct, reverberates far beyond the dollar amount of the verdict.

As Franklin’s attorney, Trent Copeland, noted, “There’s no spinning what this jury decided. Geragos may have avoided criminal charges, but a civil jury found him liable after concluding he owed our client a fiduciary duty and knowingly assisted Michael Avenatti in carrying out misconduct.”

California Bar Standards and What Comes Next

Legal experts agree: the biggest threat facing Geragos now isn’t financial, it’s professional. California attorneys are bound by the Rules of Professional Conduct, particularly:

• Rule 1.2.1 (Advising or Assisting the Violation of Law): Lawyers are prohibited from counseling or assisting a client in conduct the lawyer knows is criminal or fraudulent.
  
• Rule 8.4 (Misconduct): It is professional misconduct for a lawyer to “engage in conduct involving dishonesty, fraud, deceit, or reckless or intentional misrepresentation.”
  
• Business & Professions Code § 6106: Involves “moral turpitude, dishonesty or corruption.” A finding of moral turpitude can be grounds for disbarment.

Given the jury’s conclusions—especially findings of aiding and abetting, and knowing participation in a scheme to extort—a formal review by the California State Bar seems not just possible, but likely.

Potential Outcomes for Geragos:

• Public reproval or suspension
• Mandatory ethics training or probation
• Disbarment, if the conduct is found egregious enough

If disciplinary proceedings are initiated, the findings of the civil jury—especially as they relate to breaches of fiduciary duty and moral turpitude—could weigh heavily against Geragos.

Plaintiff Wins—No Matter the Amount

Despite the comparatively modest $100,000 damages award, this case sets a lasting precedent. In civil litigation, the “prevailing party” is the one who wins any positive judgment, even if the amount is symbolic. Here, Franklin is legally the winner. As any seasoned litigator knows, a win is a win—even if your adversary smiles for the cameras and claims otherwise.

Trent Copeland, who represented Franklin, said the $100,000 award was “less substantial than we believe the evidence proved” but a win nonetheless.

The real contest for Geragos is just beginning. As the legal maxim goes, “Justice delayed is justice denied”—but justice may be only just beginning to catch up with Mark Geragos.