In Religious Technology Center v. Gerbode, 1994 WL 228607 (C.D. Cal. 1994) (against Frank A. Gerbode, inventor of Traumatic Incident Reduction), a Rule 11 sanction of $8,887.50 was imposed against Helena Kobrin, an attorney for the Church, for bringing baseless and frivolous claims.
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Karno, along with fellow attorneys Meade Emory, James Q. Fisher, and Sherman and Stephen Lenske were reportedly involved in the Church's battle against the Internal Revenue Service during Operation Snow White.