In re Renae Ehler

Summary

The Supreme Court of Missouri disbarred Renae Lynn Ehler for multiple violations of the Missouri Rules of Professional Conduct arising from her representation of clients in a dissolution proceeding and a civil action. The Court found violations involving competence, diligence, communication, safekeeping and misappropriation of client funds, and professional misconduct. Aggravating factors included prior discipline, repeated misconduct, dishonest motive, and failure to make restitution.

Holdings

1. Ehler violated Rule 4-1.1 by failing to competently calculate and distribute marital-property proceeds and by failing to provide her client with discovery necessary to defend the water-bill lawsuit.
2. Ehler violated Rule 4-1.3 by failing to timely distribute funds owed to R.K. and H.M. and by failing to provide discovery information necessary to prevent a default judgment against C.G.
3. Ehler violated Rule 4-1.4 by failing to keep R.K. reasonably informed and by failing to respond promptly to requests for information from R.K. and H.M.'s counsel.
4. Ehler violated Rule 4-1.15 by failing to maintain adequate trust-account records, failing to provide an accounting, failing to promptly deliver client and third-party funds, and using trust-account funds to pay personal and office expenses.
5. Ehler violated Rule 4-8.4(a) by violating other Rules of Professional Conduct and violated Rule 4-8.4(c) by knowingly using client funds to pay personal expenses.
6. Disbarment was warranted because Ehler knowingly misappropriated client funds, engaged in a pattern of neglect and multiple misconduct, caused financial harm, had prior similar discipline, and repeated the misconduct during probation.

Questions Presented

1. Whether the evidence established that Ehler violated Rule 4-1.1 by failing to provide competent representation.
2. Whether the evidence established that Ehler violated Rule 4-1.3 by failing to act with reasonable diligence and promptness.
3. Whether the evidence established that Ehler violated Rule 4-1.4 by failing to communicate with clients and opposing counsel.
4. Whether the evidence established that Ehler violated Rule 4-1.15 by mishandling and misappropriating client and third-party funds and failing to maintain required trust-account records.
5. Whether the evidence established that Ehler violated Rule 4-8.4 by violating the Rules of Professional Conduct and engaging in dishonest, deceitful, or misrepresentative conduct.
6. What sanction was appropriate in light of the misconduct, prior discipline, aggravating and mitigating factors, and progressive discipline.

Disposition

other