Cited by

–67 (Minn. 2008) (applying Minnesota law to determine the discipline to impose after concluding that the Minnesota and North Dakota Rules of Professional Conduct applied to a lawyer’s conduct); Rule 15(a), RLPR.

v. Beckler, In re Disciplinary Action Against Overboe , n.5 (Minn. 2008).

And the genealogical record of citations begetting citations goes on: In re Overboe , , 867 (Minn. 2008) (accepting without analysis a referee's conclusion that "substantial experience" was an aggravating factor, citing Holker ); In re Lyons , , 636-37 (Minn. 2010) (accepting without analysis a referee's conclusion that "substantial experience" was an aggravating factor, citing Moeller a

Cf. In re Rebeau , , 176 (Minn. 2010) (citing In re Overboe , , 867 (Minn. 2008) ).

(“We have generally ‘considered the absence of harm to clients to be a mitigating factor in discipline cases.’ ” ()).

6 To the contrary, since our repeal of the conditional- 6 Riehm also cites and

In re Overboe (Overboe I), 1 Overboe did not seek reinstatement, and is currently suspended in Minnesota.

(stating that trust account violations “almost invariably result in lengthy suspension at the very least”)..

We have generally “considered the absence of harm to clients to be a mitigating factor in discipline cases.”

Trust account violations alone generally lead to suspensions; indeed, we have said that “ ‘misuse of trust accounts will almost invariably result in lengthy suspension at the very least and disbarment at worst.’ ” (quoting In re Kinnunen, 5 , 775 (Minn.1993)).