Disciplinary Board v. Merkens

2025 ND 149 · North Dakota Supreme Court · September 22, 2025 · No. Nos. 20250300-20250302

Summary

The North Dakota Supreme Court adopted a hearing panel’s recommendation to transfer attorney Paul J. Merkens from interim suspension to disability incapacity status under the state's lawyer discipline rules. Merkens stipulated to the transfer, acknowledging he may petition for reinstatement once he demonstrates improved management of his mental health and addiction recovery. The court terminated his interim suspension, ordered his participation in the North Dakota Lawyers Assistance Program, and assessed $250 in costs.

Court
North Dakota Supreme Court
Writing for the Court
Jon J. Jensen, C.J.; Daniel J. Crothers; Lisa Fair McEvers; Jerod E. Tufte; Douglas A. Bahr
Jurisdiction
North Dakota
Decision date
September 22, 2025
Docket number
Nos. 20250300-20250302
Procedural posture
Application for disciplinary action seeking transfer from interim suspension to disability incapacity status.
Precedential value
published
Parties
Disciplinary Board v. Paul J. Merkens
Disposition
other

Topics

agency adjudicationjudicial review of agency actionadministrative law

Practice areas

administrative law

Questions Presented

  1. Whether Merkens should be transferred from interim suspension to disability incapacity status under N.D.R. Lawyer Discipl. 5.1(C).

Holdings

  1. Merkens is transferred from interim suspension to disability incapacity status under N.D.R. Lawyer Discipl. 5.1(C).

Key quotations

IT IS ORDERED that as outlined above, the findings of fact, conclusions of law, and recommendations by the hearing panel are adopted. (149)
IT IS FURTHER ORDERED that Paul J. Merkens is transferred from interim suspension to disability incapacity status under N.D.R. Lawyer Discipl. 5.1(C) until further order of this Court. (149)

Factual background

Paul J. Merkens was admitted to the North Dakota bar on May 3, 2012. His license was interim suspended on September 26, 2024 pending final disposition of the disciplinary proceeding. The hearing panel found Merkens eligible for transfer to disability incapacity status.

Procedural history

The disciplinary board hearing panel recommended that Merkens be transferred to incapacitated status under N.D.R. Lawyer Discipl. 5.1(C). The Supreme Court adopted the panel's findings and ordered the transfer.

Court Document

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