State ex rel. Oklahoma Bar Ass'n v. Patterson

Summary

The Oklahoma Supreme Court considers reciprocal discipline imposed after the United States Court of Appeals for the Tenth Circuit disbarred William J. Patterson. The court holds that the record permits meaningful de novo review and imposes public censure, together with payment of proceeding costs, rather than reciprocal disbarment.

Holdings

1. The record was sufficient to permit meaningful de novo consideration of the relevant facts and the appropriate discipline.
2. In a reciprocal disciplinary proceeding, the underlying misconduct adjudicated in the other jurisdiction cannot be relitigated; it may be reviewed only within the limited framework and evidentiary materials permitted by RGDP Rule 7.7(b).
3. Public censure and payment of the costs of the proceeding were the appropriate discipline for Patterson's violations.

Questions Presented

1. Whether the record contained sufficient evidence for a meaningful de novo review of the charges and the appropriate disposition in the reciprocal disciplinary proceeding.
2. Whether public censure, together with payment of proceeding costs, was an appropriate sanction for Patterson's professional misconduct.

Disposition

other