State ex rel. Counsel for Discipline of the Nebraska Supreme Court v. Joseph P. Cullan

Summary

The Nebraska Supreme Court granted the Counsel for Discipline’s motion for reciprocal discipline against Joseph P. Cullan. Following an Iowa public reprimand for misrepresenting his prior disciplinary history in a pro hac vice application, the court imposed the same sanction and ordered payment of applicable costs and expenses.

Holdings

1. A judicial determination of attorney misconduct in another jurisdiction is generally conclusive proof of guilt in a reciprocal-discipline proceeding and is not subject to relitigation in Nebraska.
2. Public reprimand was appropriate, and the Nebraska Supreme Court imposed the same public reprimand entered by the Iowa Supreme Court.

Questions Presented

1. Whether the Nebraska Supreme Court should grant the Counsel for Discipline's motion for reciprocal discipline based on the Iowa public reprimand.
2. What discipline was appropriate under the circumstances.

Disposition

other