Summary
The Oklahoma Supreme Court granted Glen L. Work’s petition for reinstatement to membership in the Oklahoma Bar Association and the Roll of Attorneys. The court held that Work established good moral character, had not engaged in unauthorized practice in Oklahoma, maintained professional competence, and satisfied the other reinstatement requirements, subject to payment of current dues and completion of 2021 continuing legal education requirements.
Topics
Practice areas
Questions Presented
- Whether Work proved by clear and convincing evidence that he possessed the moral character required for reinstatement.
- Whether Work engaged in the unauthorized practice of law in Oklahoma after his Oklahoma license was suspended.
- Whether Work demonstrated sufficient competency and learning in the law to avoid retaking the Oklahoma Bar Examination.
- Whether Work satisfied the other requirements for reinstatement.
- Whether Work should be reinstated to membership in the Oklahoma Bar Association and to the Roll of Attorneys.
Holdings
- The Supreme Court has a nondelegable constitutional obligation to regulate the practice of law and reviews reinstatement proceedings de novo; the Professional Responsibility Tribunal's findings are advisory and not binding.
- An applicant for reinstatement must prove by clear and convincing evidence that, if readmitted, the applicant's conduct will conform to the high standards required of members of the bar, and must present stronger proof of qualifications than an applicant seeking admission for the first time.
- Work demonstrated by clear and convincing evidence the good moral character necessary for readmission.
- Work proved by clear and convincing evidence that he had not engaged in the unauthorized practice of law in Oklahoma after his license was suspended.
- Work demonstrated sufficient competency and learning in the law and therefore was not required to retake the Oklahoma Bar Examination as a condition of reinstatement.
- Work satisfied the remaining reinstatement requirements, including payment of delinquent dues, fees, and reinstatement costs, subject to payment of the current year's membership dues and completion of 2021 continuing legal education requirements.
Key quotations
“Although the findings of the PRT are given great weight, its findings are not binding on this Court, and its recommendation is merely advisory.” (¶ 7)
“Petitioner has demonstrated by clear and convincing evidence his eligibility for reinstatement without examination.” (¶ 20)
Factual background
Glen L. Work was admitted to the Oklahoma Bar in 2010 and practiced there for approximately one year before returning to Texas. His Oklahoma license was suspended in 2014 and he was stricken from the Roll of Attorneys in 2015 for failure to pay dues. Work remained an active Texas attorney but received a private reprimand in 2019 for failing to return unearned fees promptly and failing to timely respond to disciplinary complaints. He presented evidence of good moral character, continuing legal education, professional competence, and payment of delinquent dues and reinstatement costs.
Procedural history
Work petitioned the Oklahoma Supreme Court for reinstatement after his Oklahoma license was suspended for failure to pay dues and he was later stricken from the Roll of Attorneys. The Professional Responsibility Tribunal held a hearing and unanimously recommended reinstatement. The Oklahoma Bar Association did not oppose reinstatement, and the Supreme Court independently reviewed the record.