In the Matter of Douglas A. Patterson

Summary

The Supreme Court of Kansas imposed an indefinite suspension on Douglas A. Patterson based on his Missouri disbarment and failure to cooperate with Kansas disciplinary proceedings. The court conditioned any future Kansas reinstatement application on proof that Patterson had first been reinstated to practice law in Missouri.

Holdings

1. Patterson's failure to respond to the Kansas disciplinary complaint and failure to appear in the disciplinary proceedings violated KRPC 8.1(b), KRPC 8.3(a), Supreme Court Rule 207(b), and Supreme Court Rule 211(b).
2. A valid Missouri default disbarment satisfied the grounds for reciprocal discipline in Kansas under Supreme Court Rule 202 and conclusively established the underlying misconduct for purposes of the Kansas disciplinary proceeding.
3. The Missouri information and default judgment did not constitute clear and convincing evidence that Patterson violated KRPC 8.4.
4. Indefinite suspension from the practice of law in Kansas was appropriate, with reinstatement conditioned on proof that Patterson had been reinstated to practice law in Missouri.

Questions Presented

1. Whether Patterson violated Kansas disciplinary rules by failing to respond to the Kansas formal complaint and failing to participate in the disciplinary proceedings.
2. Whether the Missouri default disbarment established grounds for reciprocal discipline in Kansas under Supreme Court Rule 202.
3. Whether the Missouri information and default order constituted clear and convincing evidence that Patterson violated Kansas Supreme Court Rule 8.4.
4. What discipline should be imposed for the established violations.

Disposition

other