Cited by
Opinions in Minnesota that cite In Re Disciplinary Action Against Rhodes, 740 N.W.2d 574.
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In re Petition for Disciplinary Action against, Bradley J. Haddy, a Minnesota Attorney, Registration No. 0387503. ...
Minn. 2026
“We have repeatedly warned that a continuing pattern of client neglect is serious misconduct often warranting indefinite suspension by itself and that more extreme cases involving client neglect and failure to communicate with clients may merit disbarment.” ().
- In re Petition for Disciplinary Action against Ana L. Pena, a Minnesota Attorney, Registration No. 0386459 Minn. 2025
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In re Petition for Disciplinary Action against Ana L. Pena, a Minnesota Attorney, Registration No. 0386459
Minn. 2025
“Accordingly, we consider a lawyer’s prior discipline and professional misconduct when determining the appropriate discipline for new misconduct.”
- In re Petition for Disciplinary Action against Kristi D. McNeilly, a Minnesota Attorney, Registration No. 0341265. ... Minn. 2025
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In re Petition for Disciplinary Action against Kristi D. McNeilly, a Minnesota Attorney, Registration No. 0341265. ...
Minn. 2025
d 278, 284 (Minn. 2024).
- In re Petition for Disciplinary Action against Michael B. Padden, a Minnesota Attorney, Registration No. 0177519. ... Minn. 2024
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In re Petition for Disciplinary Action against Michael B. Padden, a Minnesota Attorney, Registration No. 0177519. ...
Minn. 2024
Misappropriation alone “usually warrants disbarment absent clear and convincing evidence of substantial mitigating factors.” (citation omitted) (internal quotation marks omitted).
- In re Petition for Disciplinary Action against James V. Bradley, a Minnesota Attorney, Registration No. 0392102. ... 7 N.W.3d 604 Minn. 2024
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In re Petition for Disciplinary Action against James V. Bradley, a Minnesota Attorney, Registration No. 0392102. ...
7 N.W.3d 604
Minn. 2024
Misappropriation alone “usually warrants disbarment absent clear and convincing evidence of substantial mitigating factors.” (citation omitted) (internal quotation marks omitted).
- In re Petition for Disciplinary Action against Fong E. Lee, a Minnesota Attorney, Registration No. 0387546 Minn. 2024
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In re Petition for Disciplinary Action against Fong E. Lee, a Minnesota Attorney, Registration No. 0387546
Minn. 2024
Misappropriation alone “usually warrants disbarment absent clear and convincing evidence of substantial mitigating factors.” (citation omitted) (internal quotation marks omitted).
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Original Jurisdiction Per Curiam Concurring, Thissen, J. In re Petition for Disciplinary Action against Ignatius Chukwuemeka Udeani, a …
Minn. 2023
Next, we consider “the cumulative weight of all of the professional misconduct in determining the appropriate sanction.”
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Distinguished
In re Petition for Disciplinary Action against
Minn. 2023
Failure to cooperate with a disciplinary investigation can “warrant indefinite suspension on its own” and “increase the severity of the disciplinary sanction when connected with other professional misconduct.”
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Original Jurisdiction Per Curiam
Minn. 2022
–65 (Minn. 1997) (stating that “repeated failure to comply with court orders” is a “serious violation” that itself is a ground for disbarment); see also In re Rhodes, 13 (concluding that failure to cooperate with the Director’s investigation was “serious misconduct” that is “separate grounds for discipline”).
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Original Jurisdiction Per Curiam
Minn. 2021
See, (“Misappropriation of client funds alone ‘is particularly serious misconduct and usua lly warrants disbarment absent clear and convincing evidence of substan tial mitigating factors.’ ” (quoting In re Rhodes, 10 )).
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In re Petition for Disciplinary Action against Ignatius Chukwuemeka Udeani,
Minn. 2020
“We do not impose disciplinary sanctions to punish a lawyer; rather, we do so ‘to protect the public, to guard the administration of justice and to deter future misconduct’ by both the individual lawyer and by othe r members of the legal profession.” (quoting In re Grzybek , ).
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In re Petition for Disciplinary Action against Karlowba R. Adams Powell, a Minnesota
Minn. 2020
Persi stent failure to cooperate with the Director’s investigation is “serious misconduct that constitutes separate grounds for discipline” and “increase[s] the severi ty of the discip linary sanctio n when connected with other professional misconduct.” In re Rhodes , –80 (Minn. 2007).
- In re Amoun Vang Sayaovong 909 N.W.2d 575 Minn. 2018
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In re Amoun Vang Sayaovong
909 N.W.2d 575
Minn. 2018
In re Rhodes , , 578 (Minn. 2007) (citations omitted) (internal quotation marks omitted) (alteration omitted).
- In re Disciplinary Action Against Tigue 900 N.W.2d 424 Minn. 2017
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In re Disciplinary Action Against Tigue
900 N.W.2d 424
Minn. 2017
We recognize that misappropriation “ ‘is particularly serious misconduct and usually warrants disbarment absent clear and convincing evidence of substantial mitigating factors.’ ” Garcia, d at 443 ().
- In re Disciplinary Action Against Saltzstein 896 N.W.2d 864 Minn. 2017
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In re Disciplinary Action Against Saltzstein
896 N.W.2d 864
Minn. 2017
(stating that a “ ‘continuing pattern of client neglect is serious misconduct often warranting indefinite suspension by itself ...
- In re Disciplinary Action Against Fahrenholtz 896 N.W.2d 845 Minn. 2017
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In re Disciplinary Action Against Fahrenholtz
896 N.W.2d 845
Minn. 2017
“Misappropriation of client funds alone is ‘particularly serious misconduct and usually warrants disbarment absent clear and convincing evidence of substantial mitigating factors.’” 2 ().
- In RE Petition for DISCIPLINARY ACTION AGAINST Jesse David MATSON, a Minnesota Attorney, Registration No. 0389131 889 N.W.2d 17 Minn. 2017
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In RE Petition for DISCIPLINARY ACTION AGAINST Jesse David MATSON, a Minnesota Attorney, Registration No. 0389131
889 N.W.2d 17
Minn. 2017
Matson’s misappropriation of C.B.’s $550 filing fee, by itself, is “ ‘particularly serious misconduct and usually warrants disbarment absent clear and convincing evidence of substantial mitigating factors.’ ” ( (internal quotation marks omitted); (disbarring an attorney who misappropriated client funds by performing no work on a matter and not returning unearned funds to the client, among other violations).
- In re Disciplinary Action Against Taplin 837 N.W.2d 306 Minn. 2013
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In re Disciplinary Action Against Taplin
837 N.W.2d 306
Minn. 2013
(“We have said that ‘[a] continuing pattern of client neglect is serious misconduct often warranting indefinite suspension by itself....’”) (); (“Repeated neglect of client matters, misrepresentations, and failure to communicate with clients typically warrant indefinite suspension.”).
- In re Disciplinary Action Against Jaeger 834 N.W.2d 705 Minn. 2013
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In re Disciplinary Action Against Jaeger
834 N.W.2d 705
Minn. 2013
Persistent failure to cooperate with the Director’s investigation is additional “serious misconduct that constitutes separate grounds for discipline” and “increase[s] the severity of the disciplinary sanction when connected with other professional misconduct.” -80 (Minn.2007).
- In re Disciplinary Action Against Fru 829 N.W.2d 379 Minn. 2013
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In re Disciplinary Action Against Fru
829 N.W.2d 379
Minn. 2013
We have said that “[a] continuing pattern of client neglect is serious misconduct often warranting indefinite suspension by itself, and that more extreme cases involving client neglect and failure to communicate with clients may merit disbarment.” (citations omitted) (internal quotation marks omitted).
- In re Disciplinary Action Against Wolff 810 N.W.2d 312 Minn. 2012
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In re Disciplinary Action Against Wolff
810 N.W.2d 312
Minn. 2012
We have held that “misappropriation of client funds is particularly serious misconduct and usually warrants disbarment absent clear and convincing evidence of substantial mitigating factors.” (citation omitted) (internal quotation marks omitted); -47 (Minn.2011) (holding that an attorney should not be disbarred for misappropriation of client funds where there were no aggravating factors, the attorney’s clients did not suffer actual harm, and the a
- In re Disciplinary Action Against Rymanowski 809 N.W.2d 217 Minn. 2012
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In re Disciplinary Action Against Rymanowski
809 N.W.2d 217
Minn. 2012
See ("Misappropriation of client funds alone 'is particularly serious misconduct and usually warrants disbarment absent clear and convincing evidence of substantial mitigating factors."" ()).
- In re Disciplinary Action Against Swokowski 796 N.W.2d 317 Minn. 2011
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In re Disciplinary Action Against Swokowski
796 N.W.2d 317
Minn. 2011
Nature of the Misconduct We have said that misappropriation of client funds alone “ ‘is particularly serious misconduct and usually warrants disbarment absent clear and convincing evidence of substantial mitigating factors.’” Garcia, d at 443 (); *327
- In re Disciplinary Action Against Garcia 792 N.W.2d 434 Minn. 2010
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In re Disciplinary Action Against Garcia
792 N.W.2d 434
Minn. 2010
Misappropriation of client funds alone “is particularly serious misconduct and usually warrants disbarment absent clear and convincing evidence of substantial mitigating factors.” (internal quotation marks omitted).
- In Re Disciplinary Action Against Rebeau 787 N.W.2d 168 Minn. 2010
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In Re Disciplinary Action Against Rebeau
787 N.W.2d 168
Minn. 2010
The misuse of a trust account is serious and will almost invariably result in a lengthy suspension or disbarment, Overboe, d at 868 (), and the misappropriation of client funds is particularly serious misconduct, usually warranting “disbarment absent clear and convincing evidence of substantial mitigating factors,” (citation omitted) (internal quotation marks omitted).
- In Re Disciplinary Action Against Aitken 787 N.W.2d 152 Minn. 2010
- In Re Disciplinary Action Against Aitken 787 N.W.2d 152 Minn. 2010
- In Re Disciplinary Action Against Albrecht 779 N.W.2d 530 Minn. 2010
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In Re Disciplinary Action Against Albrecht
779 N.W.2d 530
Minn. 2010
(“We generally impose ‘more severe sanctions when the current misconduct is similar to misconduct for which the attorney has already been disciplined.’ ” ()); d at 212 (explaining that repeated instances of similar misconduct ar
- In Re Petition for Disciplinary Action Against Anderson 759 N.W.2d 892 Minn. 2009
- In Re Petition for Disciplinary Action Against Anderson 759 N.W.2d 892 Minn. 2009
- In Re Disciplinary Action Against Redburn 746 N.W.2d 330 Minn. 2008