In re Griswold

Summary

The Kansas Supreme Court considered an uncontested attorney-discipline proceeding against Steven S. Griswold. Based on misconduct established in Missouri and additional violations of Kansas professional-conduct and court rules, the court adopted the hearing panel’s findings and recommendation and disbarred Griswold from practicing law in Kansas.

Holdings

1. Service of the formal complaint by certified mail to the respondent's most recent registration address was effective upon mailing, and service of the amended notice of hearing more than fifteen days before the hearing satisfied the applicable notice requirements, even though the respondent did not claim the certified mail.
2. A final adjudication in another jurisdiction that a lawyer committed misconduct conclusively establishes that misconduct for purposes of a Kansas disciplinary proceeding.
3. Griswold violated KRPC 1.3, 1.4(a), 3.2, 5.5(a), 8.1(b), 8.4(a), and 8.4(d), as well as Supreme Court Rule 211(b), by neglecting client matters, failing to communicate, failing to expedite litigation, practicing while not authorized, failing to respond to disciplinary authorities, engaging in related misconduct, and failing to answer the formal complaint.
4. Disbarment was warranted for Griswold's pattern of neglect, multiple professional-conduct violations, failure to cooperate with disciplinary authorities, and failure to participate in the Kansas proceeding.

Questions Presented

1. Whether service of the formal complaint and amended notice of hearing satisfied the Kansas Supreme Court Rules despite Griswold's failure to claim the certified mail.
2. Whether the Missouri disciplinary adjudication conclusively established Griswold's misconduct for purposes of the Kansas disciplinary proceeding.
3. Whether Griswold's neglect of client matters, inadequate communication, unauthorized practice, failure to cooperate with disciplinary authorities, and failure to participate in the Kansas proceeding warranted disbarment.

Disposition

other