State ex rel. Oklahoma Bar Ass'n v. Reeves (N.D. Ala. May 27, 2026)

Case details
Full caption
State of Oklahoma ex rel. Oklahoma Bar Association v. Reeves
Country
United States
Jurisdiction
Federal
Court
Northern District of Alabama (N.D. ALA)
Decided
May 27, 2026
[Respondent] cited "Williams v. Asplundh Tree Expert Co., No. 3:05-cv-479, 2006 WL 3343787, at *4 (M.D. Fla.Nov. 17, 2006)" to support the statement that, "General objections are not useful and will not be considered by theCourt. Objections should be specific and supported by a detailed explanation." Doc. 182 at 13. Though a case withthat style exists, no case with that combination of style and proposition exists. See Williams v. Asplundh TreeExpert Co., No. 3:05-cv-00479-VMC-MCR (M.D. Fla. July 23, 2013); see also Doc. 186 at 4.[Respondent] cited "United States v. Baker, 539 F.App'x 937, 943 (11th Cir 2013)" as "confirming broad discoveryrights under Rules 26 and 30." Doc. 174 at 2. As Plaintiff Johnson pointed out, "[w]hile United States v. Baker, 529Fed. Appx. 987 (11th Cir. 2013) is an actual case, it is an appeal challenging a criminal's sentencingenhancement." Doc. 186 at 2. And the case found in the Federal Appendix numbers cited by [Respondent do] notdiscuss discovery. See Williams v. Morahan, 539 F. App'x 937 (11th Cir. 2013).[Respondent] cited "Kelley v. City of Birmingham, 2021 WL 1118031, *2 (N.D. Ala. Mar. 24, 2021)" for theproposition that the district court "refus[ed] to delay deposition based on unrelated discovery issues." Doc. 174 at2. The only case with that style which Plaintiff Johnson (and the court) could find was an Alabama Court ofAppeals case from 1939 that dealt with a traffic offense. Doc. 186 at 3; see Kelley v. City of Birmingham, 28 Ala.App. 644, 189 So. 921 (Ala. Ct. App. 1939).[Respondent] cited "Greer v. Warden, FCC Coleman I, 2020 WL 3060362, at *2 (M.D. Fla. June 9, 2020)" as"rejecting inmate's request to delay deposition until additional discovery was completed." Doc. 174 at 2. This casedoes not exist, nor does a case exist with similar citation for that proposition of law. See Doc. 186 at 3.[Respondent] cited "Wilson v. Jackson, 2006 WL 8438651, at *2 (N.D. Ala. Feb. 27, 2006)" with the parentheticalthat it was an opinion "granting [a] Rule 30(a)(2)(B) motion and finding no good cause to delay deposition ofincarcerated plaintiff." Doc. 174 at 2. There is no such case, and that Westlaw number directs to a maritimepersonal injury case that does not discuss discovery. See Douglas v. Ingram Barge Co., No. CV 3:04-0383, 2006WL 8438651 (S.D.W. Va. Sept. 15, 2006); see also Doc. 186 at 4.[i]n the light of repeated general warnings from federal courts about the risks of bogus citations generated by AI, aswell as the persistent specific warning, policies, and expectations of his colleagues and law firm with respect to AI,[Respondent's] misconduct was particularly egregious. Having been so extensively alerted of the risk that AI willmake things up, and having blown through all of his firm's internal controls design to protect court filing fromcounterfeit citations, [Respondent's] repeated decision to parrot citations generated by AI without verifying even oneof them reflects complete and utter disregard for his professional duty of candor. This is recklessness in theextreme, and it is tantamount to bad faith.Respondent "appeared to have fabricated citations to legal authority in his motion for leave and motion to compel'possibly through the use of generative artificial intelligence.'" Sanctions Ord. 4; App'x to Response to Ord. to ShowCause and Br.in Response, attach. A.¶3 The United States District Court for the Northern District of Alabama Southern Division explained that there werefive problematic citations across the two motions:Sanctions Ord. 4--5, Johnson v. Dunn, Case No. 2:21-cv-1701-AMM (N.D. Ala. S. Div.) (Jul. 23, 2025) (emphasisoriginal).¶4 Respondent admitted in his response to the order to show cause from the federal court that the citations werehallucinated by ChatGPT. "In simpler terms, the citations were completely made up." Sanctions Ord. 1. The federalcourt found that the hallucinated citations in the two motions were false statements of law. Sanctions Ord. 25. Thecourt statedSanctions Ord. 37-38. The federal court recognized, as part of its authority for sanctions, the Alabama Rules ofProfessional Conduct, Rule 3.3 provides that "[a] lawyer shall not knowingly . . . [m]ake a false statement of materialfact or law to a tribunal." Sanctions Ord. 28. The court noted it was unclear whether Rule 3.3 applied there becausethe rule states it applies to "knowing misstatements of law" and the false statements in the case occurred because offailure to verify the hallucinated citations. Id., at 31. Further, the Alabama Supreme Court had "not yet had the
opportunity to consider whether Rule 3.3 applies to this specific kind of misconduct." Sanctions Ord. 31. The courtfound appropriate sanctions were public reprimand, paired with a publication requirement, disqualification in the case,and referral to state licensing authorities. Id., at 50.¶5 On November 4, 2025, the Board of Disciplinary Appeals appointed by the Supreme Court of Texas issued anAgreed Judgment of Public Reprimand against Respondent. The Texas board laid out the misconduct before thefederal court and found reciprocal discipline in the form of a public reprimand to be proper. No specific rule violationswere stated.¶6 On December 15, 2025, the Board of Professional Responsibility of the Supreme Court of Tennessee issued apublic censure against Respondent. The Tennessee censure found that Respondent "failed to act with diligence andcaused a delay in his client's case. In addition, [Respondent's] conduct was prejudicial to the administration ofjustice." Tennessee censured Respondent for violating Tennessee Rules of Professional Conduct 1.3 (diligence), 3.2(expediting litigation), and 8.4 (misconduct).¶7 On March 6, 2026, the Disciplinary Commission of the Alabama State Bar publicly reprimanded Respondent. TheAlabama Commission concluded that Respondent violated Rule 1.1. (Competence), 3.3 (Candor Toward theTribunal), and 8.4(d) and (g) (Misconduct-prejudice to administration of justice and adversely reflects on fitness topractice law) with his actions in federal court. The Alabama Bar also taxed all costs against Respondent.¶8 On December 3, 2025, and April 3, 2026, we ordered Respondent to show cause why we should not impose a finalorder of discipline and allowed him to explain his conduct or attempt to mitigate any discipline we might impose.Respondent admitted that he reviewed and revised two filings which were originally drafted by another attorney in hisoffice, a Motion for Leave to Depose Incarcerated Persons and Opposed Motion to Compel. Respondent stated thatduring his review of both documents, he noted that there were correct propositions of law that were unsupported orhad only one citation included. Respondent admitted he used the generative artificial intelligence (AI) known asChatGPT to obtain five citations which he added to those two documents. Respondent explained that in his priorusage of ChatGPT he had not experienced any material inaccuracies in the information he received; and in hishaste to improve the drafts, he failed to verify the ChatGPT citations through independent review. Respondentapologized to the judge, the parties, and counsel for his actions, and requested leave to file an amended motion withcorrected citations. Since being sanctioned, Respondent has worked with opposing counsel from the case thisoccurred within in order to develop a program to educate law students regarding the risks of AI.1¶9 Respondent received a sanctions order in the United States District Court for the Northern District of Alabama inFrankie Johnson v. Jefferson Dunn, et al., Case No. 2:21-cv-1701-AMM on July 23, 2025, for failing to verify the fivecitations he obtained through ChatGPT and included in two filed documents. Respondent self-reported the sanctionsorder to all states he was admitted to practice law in on July 25, 2025. In Texas, Respondent agreed to the publicreprimand, thereby foregoing a hearing. The Texas Board of Disciplinary Appeals issued an agreed reciprocaldiscipline action based on the sanctions from Alabama, not any separate action or misbehavior. Respondent does notcontest this Court's consideration of the Texas reprimand for reciprocal discipline.¶10 Respondent disputes that the Tennessee censure lacks an adequate or reasonable legal or evidentiary basis todemonstrate that he violated Tennessee Rules of Professional Conduct 1.3, 3.2, or 8.4. Supp. Resp. to Ord. to ShowCause 3. Respondent argues that contrary to Oklahoma RGDP 7.7, the Tennessee censure does not supply a factualor analytical basis sufficient to presume the validity of the finding and conclusions in the censure or to supportreciprocal or additional discipline. According to the OBA, Respondent did not contest the imposition of public censurein Tennessee and did not appeal the decision of the board.¶11 Respondent disputes the Alabama State Bar's public reprimand for this same act, which they found to be inviolation of Alabama Rules 1.1 (Competence), 3.3 (Candor Toward the Tribunal), and 8.4(d) and (g) (Misconduct).Respondent asserts that nothing in the reprimand demonstrates Respondent's lack of legal knowledge orincompetence in filing the two motions. Respondent claims that the motions did not alter the procedural posture of thecase, delay its resolution, or prejudice any party. He further asserts that he did not attempt or intend to engage inconduct prejudicial to the administration of justice. Respondent stated that he did not have actual knowledge of anyhallucinated citations in the motions before filing them. Second Supp. Response to Ord. to Show Cause 3.Respondent maintains that nothing in the Alabama reprimand reflects clear and convincing evidence of any ruleviolation. The OBA noted that in Alabama, an attorney may accept the reprimand, request a reconsideration, or refuse
and demand formal charges by filed and a hearing held. Complainant's Response to Respondent's Second Supp.Response to Ord. to Show Cause, filed May 5, 2026. The OBA noted that the Alabama Disciplinary Commissionproperly notified Respondent and he "did not contest the issuance of the reprimand, challenge the rule violations, norrequest formal charges be filed. Id., at 3.¶12 The OBA states Respondent violated ORPC 1.3, 3.2, and 8.4(d) and RGDP 1.3. Recommendation ofDiscipline 5. The OBA notes that this is the first reported attorney discipline case in Oklahoma involving fabricatedcitations from artificial intelligence and an attorney's failure to verify them before relying on the false citations in filedpleadings. The OBA thus cited to several federal cases regarding appropriate discipline. The OBA recommendationfor reciprocal discipline is the same discipline that Respondent has received in the other jurisdictions for his actions:public reprimand.2345II. STANDARD OF REVIEW¶13 This Court is vested with exclusive, original, and nondelegable jurisdiction over attorney-discipline cases. Stateex rel. Okla. Bar Ass'n v. Hart, 2014 OK 96 (deliverdocument.asp?citeid=474848), 6, 339 P.3d 895(deliverdocument.asp?citeid=474848), 898. As we have announced in numerous decisions, "[t]he ultimateresponsibility for deciding whether misconduct has occurred and what discipline is warranted if misconduct is foundrests with [this Court] in the exercise of our exclusive original jurisdiction in bar disciplinary matters." State ex rel.Okla. Bar Ass'n v. Cox, 2011 OK 73 (deliverdocument.asp?citeid=463781), 10, 257 P.3d 1005(deliverdocument.asp?citeid=463781), 1008 (quoting State ex rel. Okla. Bar Ass'n v. Taylor, 2003 OK 56(deliverdocument.asp?citeid=435629), 2, 71 P.3d 18 (deliverdocument.asp?citeid=435629), 21) (alteration in Cox).¶14 The sanctions order issued by the United States District Court for the Northern District of Alabama, the AgreedJudgment of Public Reprimand issued by the Board of Disciplinary Appeals for the Supreme Court of Texas, thePublic Censure issued by the Board of Professional Responsibility of the Supreme Court of Tennessee, and thePublic Reprimand issued by the Disciplinary Commission of the Alabama State Bar constitute the charges againstRespondent and are prima facie evidence that Respondent committed the acts described therein. RGDP 7.7(c); Stateex rel. Okla. Bar Ass'n v. Henderson, 1999 OK 29 (deliverdocument.asp?citeid=60781), 4, 977 P.2d 1096(deliverdocument.asp?citeid=60781), 1098. Respondent bears the burden of proof to show that the findings formingthe basis of his discipline were not supported by the evidence or that the findings are not sufficient grounds fordiscipline in Oklahoma. Henderson, 1999 OK 29 (deliverdocument.asp?citeid=60781), 4, 977 P.2d, at 1098.¶15 Respondent attached a copy of the federal sanction he received, the two motions he filed in federal court withfalse citations which led to his discipline, his response to the federal court, his firm and co-counsel's response to thefederal court, and the transcript from the federal show-cause hearing. Respondent did not submit any transcripts orother evidence from the other three jurisdictions' reciprocal discipline proceedings. Respondent also waived his rightto a hearing in Oklahoma.III. ANALYSIS16 There is nothing inherently problematic with the use of generative artificial intelligence in preparing legalmaterials, so long as attorneys abide by their duty to protect client confidentiality and recall their sacred duty to verifythe pleadings they sign. The careless use of generative artificial intelligence to "save time" by not independentlyconfirming citations is instead a waste of judicial resources and opposing party's time and money. It also damages theintegrity and credibility of the legal system. Human diligence and review is required to ensure content and accuracy offiled documents. Signing pleadings that contain citations from generative AI that have not been verified shows areckless disregard for the truth and an indifference to accuracy.¶17 Respondent's claim that the Tennessee public censure and Alabama public reprimand do not supply a factual oranalytical basis sufficient to presume the validity of the findings and conclusions in those proceedings or to supportreciprocal discipline are mischaracterizations of Oklahoma RGDP 7.7 and our case law. RGDP 7.7(c) states:"Certified copies of the documents shall constitute the charge and shall be prima facie evidence the lawyer committedthe acts therein described." Because the discipline from the other jurisdictions is considered prima facie evidence thatRespondent committed the acts described, it is Respondent's burden to show that he did not. RGDP 7.7(b) states:
When a lawyer is the subject of a final adjudication in a disciplinary proceeding, except contempt proceedings, inany other jurisdiction, the General Counsel of the Oklahoma Bar Association shall cause to be transmitted to theChief Justice a certified copy of such adjudication within five (5) days of receiving such documents. The ChiefJustice shall direct the lawyer to show cause in writing why a final order of discipline should not be made. A writtenresponse from the lawyer shall be verified and expressly state whether a hearing is desired. The lawyer may in theinterest of explaining his or her conduct, or by way of mitigating the discipline to be imposed upon him or her,submit a brief and/or any evidence tending to mitigate the severity of discipline. The lawyer may submit a certifiedcopy of any transcripts of the evidence taken during disciplinary proceedings in the other jurisdiction to supporthis/her claim that the finding therein was not supported by the evidence or that it does not furnish sufficient groundsfor discipline in Oklahoma. The General Counsel may respond by submission of a brief and/or any evidencesupporting a recommendation of discipline.I was aware of the limitations on use; and in this instance, these two instances, I did not comply for the policy. Andfor that, I am apologetic. There was no excuse for it. There's no way to justify it. I can explain, but that doesn't helpthe process.Respondent chose to not file any evidence to mitigate or support his claim of insufficient evidence. The lack of lengthydescriptions in the public reprimand and public censure are not proof that the conclusions are inaccurate; the federalsanctions order they both reference sets out the harms to other parties that occurred because of this misconduct. SeeSanction Ord. 24. Further, "Respondent may not deny the effect of his decision not to contest the charges madeagainst him in [other jurisdictions] by arguing now that there has been no evidentiary hearing."State ex rel. Okla. Bar Ass'n v. Bransgrove, 1998 OK 93 (deliverdocument.asp?citeid=60548), 6, 976 P.2d 540(deliverdocument.asp?citeid=60548), 541.¶18 The record shows that the federal judge found Respondent showed "complete and utter disregard for hisprofessional duty of candor." Sanctions Ord. 38. Respondent argues that his misconduct was not a violation of ORPC3.3 because he did not knowingly misrepresent facts or law in the filed motions. In Krug, we clarified that underORPC 3.3, "a person's knowledge may be inferred from circumstances." State ex rel. Okla. Bar Ass'n v. Krug, 2004OK 28 (deliverdocument.asp?citeid=438678), 12, 92 P.3d 67 (deliverdocument.asp?citeid=438678), 71; see alsoORPC, 5 O.S.2025, ch. 1, App. 3-A, Rule 1.0(f) (defining "knowingly" as denoting "actual knowledge of the fact inquestion. A person's knowledge may be inferred from circumstances."). This would be such a case.6¶19 Respondent's firm had a policy under which "the use of ChatGPT for legal research require[d] written approvalfrom a practice group leader." Sanctions Ord. 16 (quoting firm partner's declaration). The partner (and practice leader)that was involved in this case for Respondent's firm stated in his declaration that "our firm has made the limitationsupon the use of artificial intelligence abundantly clear to all of our attorneys." Sanctions Ord. 16--17. The firmintroduced evidence that in June 2023, "all [firm] attorneys received an email 'stating that "there are significant risksthat LLM [Large Language Model] output can appear perfectly researched and logical while in fact it is whollyinaccurate." That same email implemented a policy which requires "written permission from the appropriate PracticeGroup Leader to use this new technology as a secondary research tool, with full checks of the accuracy of any resultsthrough traditional legal research methods." Respondent did not seek or gain that permission. Nor did he perform anychecks on the accuracy of his results. "Similarly, when [firm] provided its attorneys access to Westlaw's CoCounselplatform in January 2025, it 'adopted and distributed a policy' that '[a]ll outputs must be reviewed and verified by theresponsible attorney before being presented to clients, filed with courts, or otherwise relied upon.'" Sanctions Ord. 20--21. When asked about his knowledge of the firm policies, Respondent testified before the federal courtApp'x to Response to Ord. to Show Cause, Attach. H; Tr. of Show Cause Hearing 23:1--9, May 21, 2025 (N.D. Ala. S.Div.).¶20 In light of this information, Respondent's assertion that he did not have knowledge of the false citations afterusing AI to generate citations and not verifying them is hard to comprehend. Respondent was the only attorney in thecase who used AI to find citations. Respondent was the only attorney in the case who knew that he used AI. And mostimportantly, Respondent knew that he did not verify the citations that he added.
appropriate and reasonable sanction must (1) have sufficient deterrent force to make this misuse of AI unprofitablefor lawyers and litigants, (2) correspond to the extreme dereliction of professional responsibility that sham citationsreflect (whether generated by artificial or human intelligence), and (3) effectively communicate that made upauthorities have no place in a court of law.¶21 Respondent knew that his firm had a policy against using AI because AI can be inaccurate while appearingotherwise. And Respondent ignored his firm's policy that if an attorney did use AI, they should fully check the resultsthrough traditional research methods. Comment 2 to the Oklahoma Rules of Professional Conduct, Rule 3.3 statesthat an "Advocate is responsible for pleadings and other documents prepared for litigation." Respondent presentedmultiple filings to the federal court knowing that he had not verified that the claims within them were supported bycorrect case law. A lawyer's duty to not knowingly make a false statement of fact or law to a tribunal goes beyondturning a blind eye to the possibility of the content of his pleadings being false. Instead, a lawyer has a duty to verifyand ensure the accuracy of the pleadings his name is on. "All persons filing documents in Oklahoma courts areresponsible for the content and accuracy of the documents." See In re: Generative Artificial Intelligence, SCAD-2026-17. If a lawyer knowingly uses AI to generate citations or analysis for a pleading and knowingly does not verify theaccuracy before including it in the pleading, then the lawyer has knowingly made a false statement.IV. APPROPRIATE DISCIPLINE¶22 This Court may impose reciprocal discipline whenever discipline for lawyer misconduct has been imposed inanother jurisdiction. State ex rel. Okla. Bar Ass'n v. Patterson, 2001 OK 51 (deliverdocument.asp?citeid=242570), 5,28 P.3d 551 (deliverdocument.asp?citeid=242570), 554; "In a reciprocal disciplinary proceeding, it is within thisCourt's discretion to visit the same discipline as that imposed in the other jurisdiction or one of greater or lesserseverity." State ex rel. Okla. Bar Ass'n v. Kleinsmith, 2013 OK 16 (deliverdocument.asp?citeid=468681), 4, 297 P.3d1248 (deliverdocument.asp?citeid=468681), 1250 (citing State ex rel. Okla. Bar Ass'n v. Patterson, 2001 OK 51(deliverdocument.asp?citeid=242570), 33, 28 P.3d 551 (deliverdocument.asp?citeid=242570), 561). To determinethe appropriate discipline, we consider the current misconduct, past misconduct and discipline, and the purposes ofdiscipline. Our primary goal in attorney discipline is to safeguard the interest of the public, the judiciary, and the legalprofession, while trying to deter similar future misconduct by other attorneys. State ex rel. Okla. Bar Ass'n v.Kleinsmith, 2013 OK 16 (deliverdocument.asp?citeid=468681), 4, 297 P.3d 1248 (deliverdocument.asp?citeid=468681), 1250. To determine what measure of discipline is proper, we are guided by discipline imposed uponother lawyers for similar acts of professional misconduct. Id.; see also State ex rel. Okla. Bar Ass'n v. Benefield, 2005OK 75 (deliverdocument.asp?citeid=444875), 21, 125 P.3d 1191 (deliverdocument.asp?citeid=444875), 1195. Thefederal court noted that anSanction Ord. 2. We agree.¶23 Respondent argues that several mitigating factors apply before this Court. Respondent has never beendisciplined in over twenty years of practice, Respondent self-reported the initial problem to the Alabama bar's GeneralCounsel, self-reported the sanctions and other state's reprimands and censures to the OBA and made a full-and-freedisclosure, cooperating fully. Respondent also asserts that he did not rely on unverified citations from ChatGPT fordishonest or selfish motives to obtain a positive outcome for himself or his client. Respondent made a timely, good-faith effort to rectify the consequences of his misconduct. Finally, Respondent is now working to educate law studentsabout the potential dangers of AI use in the legal profession. Respondent expressed remorse and admitted that hisconduct arose from "careless reliance on AI-generated content during an extremely compressed timeframe, withoutany intent to mislead the district court or opposing counsel." Resp. to Order to Show Cause 14.¶24 The misconduct for which Respondent was censured or reprimanded in Texas, Tennessee, Alabama, andAlabama federal court--presenting false citations, obtained through use of generative AI--constitutes violations ofORPC 1.3, 3.2, 3.3, 8.4(d), and RGDP 1.3. A public reprimand is warranted in Oklahoma for the actions which formthe basis of Respondent's public reprimands in Tennessee, Alabama and Texas and in the United States District Courtfor the Northern District of Alabama Southern Division.RESPONDENT PUBLICLY REPRIMANDED.Rowe, C.J., Kuehn, V.C.J., Winchester, Edmondson, Combs, Gurich (by separate writing), Darby, Kane, and Jett, JJ.,concur
You do solemnly swear that you will support, protect and defend the Constitution of the United States, and theConstitution of the State of Oklahoma; that you will do no falsehood or consent that any be done in court, and if youknow of any you will give knowledge thereof to the judges of the court, or some one of them, that it may bereformed; you will not wittingly, willingly or knowingly promote, sue, or procure to be sued, any false or unlawful suit,or give aid or consent to the same; you will delay no man for lucre or malice, but will act in the office of attorney inthis court according to your best learning and discretion, with all good fidelity as well to the court as to your client,so help you God.(1) make a false statement of fact or law to a tribunal or fail to correct a false statement of material fact orlaw previously made to the tribunal by the lawyer;GURICH, J., with whom COMBS, J., joins concurring:I concur in the discipline imposed in this matter. The unverified use of generative artificial intelligence resulting inreliance upon false authority is reprehensible and clearly violates numerous ethical rules. I write separately toemphasis that lawyers have an ethical and professional duty to verify each citation submitted to the court in support ofany pleading, motion, or brief. I want to remind attorneys of their oath:5 O.S. § 2 (deliverdocument.asp?citeid=64829) (emphasis added). Further, 12 O.S. § 2011 (deliverdocument.asp?citeid=440621) provides that an attorney (or non-attorney) who presents to the court--whether by signing, filing,submitting or later advocating a pleading, written motion, or other paper--certifies that the submission is based uponexisting law and is not frivolous or based upon an improper motive to increase the cost of litigation, and the attorneyhas made reasonable inquiry. Sanctions are available to judges of the district court should violations occur. The hopeis that by publicly reprimanding the respondent herein, others will be deterred from the careless and unprofessionaluse of AI.FOOTNOTESDarby, J.: Respondent explained that his prior usage of ChatGPT was mainly for personal reasons such asresearching diet after surgery, family trips, and colleges for his child. App'x to Response to Ord. to ShowCause, Attach. H; Tr. of Show Cause Hearing 21:22--22:12, May 21, 2025 (N.D. Ala. S. Div.). Respondenteventually began to occasionally use ChatGPT to perform a general search on background for witnesses hewas going to depose or to research existing "policies in the corrections world" in order to help draft policies forcorrectional institutions. Id., at 22:12--22:25. Respondent testified that he primarily used Westlaw'sCoCounsel product professionally. See id., at 22:11--12.1 "A lawyer shall act with reasonable diligence and promptness in representing client." Oklahoma Rules ofProfessional Conduct (ORPC), 5 O.S.2021, ch. 1, app. 3-A, Rule 1.3, Diligence.2 "A lawyer shall make reasonable efforts to expedite litigation consistent with the interests of the client."ORPC, 5 O.S.2021, ch. 1, app. 3-A, Rule 3.2, Expediting Litigation.3 "It is professional misconduct for a lawyer to . . . engage in conduct that is prejudicial to the administrationof justice . . . ." ORPC, 5 O.S.2021, ch. 1, app. 3-A, Rule 8.4(d), Misconduct.4 The commission by any lawyer of any act contrary to prescribed standards of conduct, whether in thecourse of his professional capacity, or otherwise, which act would reasonably be found to bring discredit uponthe legal profession, shall be grounds for disciplinary action, whether or not the act is a felony ormisdemeanor, or a crime at all. Conviction in a criminal proceeding is not a condition precedent to theimposition of discipline.5Rules Governing Disciplinary Proceedings (RGDP), 5 O.S.2021, ch. 1, app. 1-A, Rule 1.3. (a) A lawyer shall not knowingly:6
Citationizer Summary of Documents Citing This DocumentCiteNameLevelNone Found.Citationizer: Table of AuthorityCiteNameLevelOklahoma Supreme Court Cases CiteNameLevel 2001 OK 51 (DeliverDocument.asp?CiteID=242570), 28 P.3d 551(DeliverDocument.asp?CiteID=242570), 72 OBJ 1921(DeliverDocument.asp?CiteID=242570),STATE ex. rel. OKLAHOMA BAR ASSN. v. PATTERSON(DeliverDocument.asp?CiteID=242570)Discussed at Length 2003 OK 56 (DeliverDocument.asp?CiteID=435629), 71 P.3d 18(DeliverDocument.asp?CiteID=435629),STATE ex rel. OKLAHOMA BAR ASSOCIATION v. TAYLOR(DeliverDocument.asp?CiteID=435629)Discussed 2004 OK 28 (DeliverDocument.asp?CiteID=438678), 92 P.3d 67(DeliverDocument.asp?CiteID=438678),STATE ex rel. OKLAHOMA BAR ASSOCIATION v. KRUG(DeliverDocument.asp?CiteID=438678)Discussed 2005 OK 75 (DeliverDocument.asp?CiteID=444875), 125 P.3d 1191(DeliverDocument.asp?CiteID=444875),STATE ex rel. OKLAHOMA BAR ASSOCIATION v. BENEFIELD(DeliverDocument.asp?CiteID=444875)Discussed 2011 OK 73 (DeliverDocument.asp?CiteID=463781), 257 P.3d 1005(DeliverDocument.asp?CiteID=463781),STATE ex rel. OKLAHOMA BAR ASSOCIATION v. COX(DeliverDocument.asp?CiteID=463781)Discussed 2013 OK 16 (DeliverDocument.asp?CiteID=468681), 297 P.3d 1248(DeliverDocument.asp?CiteID=468681),STATE ex rel. OKLAHOMA BAR ASSOCIATION v. KLEINSMITH(DeliverDocument.asp?CiteID=468681)Discussed at Length 2014 OK 96 (DeliverDocument.asp?CiteID=474848), 339 P.3d 895(DeliverDocument.asp?CiteID=474848),STATE ex rel. OKLAHOMA BAR ASSOCIATION v. HART(DeliverDocument.asp?CiteID=474848)Discussed 1998 OK 93 (DeliverDocument.asp?CiteID=60548), 976 P.2d 540(DeliverDocument.asp?CiteID=60548),69 OBJ 3235 (DeliverDocument.asp?CiteID=60548),State of Oklahoma ex rel. Oklahoma Bar Association v. Bransgrove(DeliverDocument.asp?CiteID=60548)DiscussedOklahoma Rules of Professional Conduct (ORPC), 5 O.S.2021, ch. 1, app. 3-A, Rule 3.3(a)(1), CandorToward the Tribunal.©
CiteNameLevel 1999 OK 29 (DeliverDocument.asp?CiteID=60781), 977 P.2d 1096(DeliverDocument.asp?CiteID=60781),70 OBJ 1134 (DeliverDocument.asp?CiteID=60781),State ex. rel. Oklahoma Bar Association v. Henderson (DeliverDocument.asp?CiteID=60781)Discussed at LengthTitle 5. Attorneys and the State Bar CiteNameLevel 5 O.S. 2 (DeliverDocument.asp?CiteID=64829),Attorney's Oath (DeliverDocument.asp?CiteID=64829)CitedTitle 12. Civil Procedure CiteNameLevel 12 O.S. 2011 (DeliverDocument.asp?CiteID=440621),Signing of Pleadings (DeliverDocument.asp?CiteID=440621)Cited
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