Colo. RPC 8.4

History

Source: Committee comment amended October 17, 1996, effective January 1, 1997; entire Appendix repealed and readopted April 12, 2007, effective January 1, 2008; (c) amended and adopted, effective September 28, 2017; (g) and (h) amended, (i) added, and committee comment [5A] added, effective September 19, 2019; (c) amended effective December 6, 2019. COMMENT [1] Lawyers are subject to discipline when they violate or attempt to violate the Rules of Professional Conduct, knowingly assist or in- duce another to do so or do so through the acts of another, as when they request or instruct an agent to do so on the lawyer’s behalf. Paragraph (a), however, does not prohibit a lawyer from advising a client concerning action the client is legally entitled to take. [2] Many kinds of illegal conduct reflect adversely on fitness to practice law, such as offenses involving fraud and the offense of will- ful failure to file an income tax return. How- ever, some kinds of offenses carry no such im- plication. Traditionally, the distinction was drawn in terms of offenses involving ‘‘moral turpitude.’’ That concept can be construed to include offenses concerning some matters of personal morality, such as adultery and compa- rable offenses, that have no specific connection to fitness for the practice of law. Although a lawyer is personally answerable to the entire criminal law, a lawyer should be professionally answerable only for offenses that indicate lack of those characteristics relevant to law practice. Offenses involving violence, dishonesty, breach of trust, or serious interference with the admin- istration of justice are in that category. A pattern of repeated offenses, even ones of minor signifi- cance when considered separately, can indicate indifference to legal obligation. [3] A lawyer who, in the course of repre- senting a client, knowingly manifests by word or conduct, bias or prejudice based upon race, gender, religion, national origin, disability, age, sexual orientation or socioeconomic status, vio- lates paragraph (g) and also may violate para- graph (d). Legitimate advocacy respecting the foregoing factors does not violate paragraphs (d) or (g). A trial judge’s finding that peremp- tory challenges were exercised on a discrimina- tory basis does not alone establish a violation of this Rule. [4] A lawyer may refuse to comply with an obligation imposed by law upon a good faith belief that no valid obligation exists. The provi- sions of Rule 1.2(d) concerning a good faith challenge to the validity, scope, meaning or application of the law apply to challenges of legal regulation of the practice of law. [5] Lawyers holding public office assume legal responsibilities going beyond those of other citizens. A lawyer’s abuse of public office can suggest an inability to fulfill the profes- sional role of lawyers. The same is true of abuse of positions of private trust such as trustee, executor, administrator, guardian, agent and of- ficer, director or manager of a corporation or other organization. [5A] Sexual harassment may include, but is not limited to, sexual advances, requests for sexual favors, and other verbal or physical con- duct of a sexual nature that a reasonable person would perceive as unwelcome. The substantive law of employment discrimination, including anti-harassment statutes, regulations, and case law, may guide, but does not limit, application of paragraph (i). ‘‘Professional activities’’ are not limited to those that occur in a client-lawyer relationship. ANNOTATION Law reviews. For article, ‘‘Settlement Eth- ics’’, see 30 Colo. Law. 53 (Dec. 2001). For article, ‘‘Improper Recording of an Attorney’s Charging Lien’’, see 32 Colo. Law. 61 (Feb. 2003). For article, ‘‘Discipline Against Lawyers for Conduct Outside the Practice of Law’’, see 32 Colo. Law. 75 (Apr. 2003). For article, ‘‘En- forcing Civility: The Rules of Professional Con- duct in Deposition Settings’’, see 33 Colo. Law. 75 (Mar. 2004). For article, ‘‘Metadata: Hidden Information Microsoft Word Documents Its Ethical Implications’’, see 33 Colo. Law. 53 (Oct. 2004). For comment, ‘‘Should a Lawyer Ever Be Allowed to Lie? People v. Pautler and a Proposed Duress Exception’’, see 75 U. Colo. L. Rev. 301 (2004). For article, ‘‘The Duty of Loyalty and Preparations to Compete’’, see 34 Colo. Law. 67 (Nov. 2005). For article, ‘‘Inves- tigative Tactics: They May Be Legal, But Are They Ethical?’’, see 35 Colo. Law. 43 (Jan. 2006). For article, ‘‘The New Rules of Profes- sional Conduct: Significant Changes for In- House Counsel’’, see 36 Colo. Law. 71 (Nov. 2007). For article, ‘‘Ethics in Family Law and the New Rules of Professional Conduct’’, see 37 Colo. Law. 47 (Oct. 2008). For article, ‘‘Liti- gating Disputes Involving the Medical Mari- juana Industry’’, see 41 Colo. Law. 103 (Aug. 2012). For article, ‘‘Client-Drafted Engagement Letters and Outside Counsel Policies’’, see 43 Colo. Law. 33 (Feb. 2014). For article, ‘‘Pretext Investigations: An Ethical Dilemma for IP At- torneys’’, see 43 Colo. Law. 41 (June 2014). For article, ‘‘Out of Bounds: Boundary Issues in the Practice of Law’’, see 43 Colo. Law. 57 (Dec. 2014). For article, ‘‘Disputed Funds in the Possession of a Lawyer’’, see 44 Colo. Law. 47 (Feb. 2015). For article, ‘‘Top 10 Things In- House Lawyers Need to Know about Ethics’’, see 45 Colo. Law. 59 (July 2016). For article, ‘‘Ethical Duties of an Insurance Defense Law- yer’’, see 46 Colo. Law. 40 (Oct. 2017). For article, ‘‘Handling Electronic Documents Pur- loined by a Client’’, see 48 Colo. Law. 22 (Jan. 2019). For article, ‘‘‘Lawful Investigative Ac- tivities’ and Rule 8.4(c)’’, see 48 Colo. Law. 36 (June 2019). For article, ‘‘Prohibited by Rule: Sexual Harassment as Attorney Misconduct’’, see 49 Colo. Law. 39 (Aug.-Sept. 2020). For article, ‘‘Risking a Contact High: The Tenth Circuit’s Failure to Defer to Colorado’s Mari- juana Laws’’, see 98 Denv. L. Rev. 265 (2021). For article, ‘‘Think Before Y ou Send: Civility and Professionalism in Emails’’, see 51 Colo. Law. 8 (Feb. 2022). For article, ‘‘Unobvious Misconduct Under ’Catch-All’ Rules 8.4(c) and (d)’’, see 51 Colo. Law. 36 (Nov. 2022). Annotator’s note. Rule 8.4 is similar to Rule 8.4 as it existed prior to the 2007 repeal and readoption of the Colorado rules of professional conduct. Relevant cases construing that provi- sion have been included in the annotations to this rule. Section (g) of this rule is not unconstitu- tionally overbroad nor vague. Although this rule does prohibit some speech that would be constitutionally protected in other contexts, it prohibits such speech in furtherance of several compelling state interests and is narrowly tai- lored so that any possible unconstitutional reach is neither real nor substantial. In Matter of Abrams, 2021 CO 44, 488 P.3d 1043. Proof of a violation of section (g) does not require a demonstration that an attorney ac- tually harbors bias against a person on the basis of a protected classification. The rule only addresses the attorney’s outward behavior; it does not attempt to police whether a lawyer privately holds prejudicial beliefs. In Matter of Abrams, 2021 CO 44, 488 P.3d 1043. A hearing board always has discretion in determining the appropriate sanction for at- torney misconduct and may impose any of the forms of discipline listed in C.R.C.P. 251.6, which range from private admonition to disbar- ment. In re Attorney F, 2012 CO 57, 285 P.3d 322. Hearing board erred, therefore, in concluding that it was compelled by case law to impose a public censure instead of private admonition. In re Attorney F, 2012 CO 57, 285 P.3d 322. Conduct sufficient to satisfy the elements of § 18-8-707 (1)(a) and (1)(c) adversely re- flects on attorney’s fitness as a lawyer in contravention of section (b) of this rule. People v. Olson, 470 P.3d 789 (Colo. O.P .D.J. 2016). Attorney violated section (b) when, in an apparent effort to excuse her earlier inaction, she twice staged her own abduction and made up spurious stories of threats and menacing. Attorney was later convicted of one felony count of attempting to influence a public ser- vant and one misdemeanor count of false re- porting to authorities. People v. Keil, 470 P.3d 872 (Colo. O.P .D.J. 2016). Attorney’s refusal to return documents be- longing to client’s parents and assertion of a retaining lien constitute conduct which is prejudicial to the administration of justice. People v. Brown, 840 P.2d 1085 (Colo. 1992). Attorney’s persistence in pursuing volun- tary dismissal of client’s claim, even after client had retained other counsel and asserted an intention not to dismiss the claim, consti- tuted conduct prejudicial to the administration of justice. People v. Muhr, 370 P.3d 667 (Colo. O.P .D.J. 2015). Lawyer violated section (c) when he repre- sented loan documents to be investment agreements to circumvent a provision in the Colorado Liquor Code that restricts the cross-ownership of businesses holding liquor licenses. In re Lopez, 980 P.2d 983 (Colo. 1999). Attorneys are responsible for ethical viola- tion when their investigator surreptitiously re- corded his telephone interview with employee of defendant. Even if lawyers had no prior knowledge of the investigator’s recording, once they learned that the interview was done with- out the employee’s consent, they should not have listened to or used the recording without the employee’s consent. McClelland v. Blazin’ Wings, Inc., 675 F. Supp. 2d 1074 (D. Colo. 2009). Attorney violated sections (a) and (c) by failing to notify a client that he never paid two medical bills that he had promised to pay, re- cording a false deed of trust memorializing a purported loan from two married clients to an- other client even though the clients had un- equivocally refused to make the loan, and at- tempting to enter into a business transaction with clients without making disclosures re- quired by rule 1.8. People v. Calvert, 280 P.3d 1269 (Colo. O.P .D.J. 2011). Attorney violated section (c) when he re- ceived an insurance payout on behalf of his client, subject to a medical lien; purported to negotiate settlement of the lien for a lesser amount; reimbursed himself for expenses im- properly advanced to the client; then failed to pay any amount to the lien claimant. People v. Bath, 460 P.3d 331 (Colo. O.P .D.J. 2020). Taking for his or her own use funds that a client has paid the lawyer to cover the cost of specific services provided by a third party for the client’s benefit constitutes knowing conver- sion and violates section (c). Matter of Kleinsmith, 2017 CO 101, 409 P.3d 305. Lawyer violated section (c) when he failed to disclose the fact of his client’s death dur- ing settlement negotiations. People v. Rosen, 199 P.3d 1241 (Colo. O.P .D.J. 2007). Lawyer who misrepresented to clients his status to practice law in the state engaged in dishonest conduct in violation of section (c) of this rule. People v. Auer, 332 P.3d 136 (Colo. O.P .D.J. 2014). Failure of former district attorney to make ordered child support payments constitutes conduct prejudicial to the administration of jus- tice and conduct that adversely reflects upon a lawyer’s fitness to practice law. People v. Primavera, 904 P.2d 883 (Colo. 1995). Attorney’s nonpayment of spousal support was a violation of section (d) warranting sus- pension, but the attorney’s answer of ‘‘no’’ on his 2014 attorney registration statement regard- ing whether he was under the obligation of any current child support order did not violate sec- tion (c) because the attorney reasonably be- lieved the unallocated temporary support order in place at that time was not a child support order. People v. McQuitty, 371 P.3d 279 (Colo. O.P .D.J. 2016). Disciplinary board erred by concluding that attorney violated section (d) by failing to pay a court reporting service. Where there is no evidence that the attorney had any legal obligation to pay, an attorney’s alleged failure to pay a court reporter does not constitute con- duct prejudicial to the administration of justice. Matter of Betterton-Fike, 2020 CO 19, 459 P.3d 522. Attorney who conditioned settlement agreement on plaintiffs not pursuing a griev- ance against him violated section (d) and con- stituted conduct prejudicial to the administra- tion of justice. In re Lopez, 980 P.2d 983 (Colo. 1999). When a public defender gave his client the impression that he would provide better rep- resentation if the client hired him as private counsel, his conduct prejudiced the administra- tion of justice under section (d), for which pub- lic censure was warranted. People v. Casias, 279 P.3d 667 (Colo. O.P .D.J. 2012). Attorney signing substitute counsel’s name to pleadings in a style different from his own signature, without authority to sign in a repre- sentative capacity and without any indication that he was signing in a representative capacity, violated this rule and warranted a six-month suspension. People v. Reed, 955 P.2d 65 (Colo. 1998). A noble motive does not justify departure from any rule of professional conduct. A prosecutor trying to protect public safety is not immune from the code of professional conduct when he or she chooses deception as means for protecting public safety. In re Pautler, 47 P.3d 1175 (Colo. 2002). There is no imminent public harm, duress, or choice of evils exception or defense for a prosecutor to the rules of professional con- duct. In re Pautler, 47 P.3d 1175 (Colo. 2002). Suspension appropriate where prosecutor engaged in intentional deception in order to secure a suspect’s arrest. The prosecutor’s conduct violated the public and professional trust, was intentional, created potential harm, and involved aggravating factors, thus, justify- ing suspension. In re Pautler, 47 P.3d 1175 (Colo. 2002). When considering discipline of attorneys who criticize judges, the New Y ork Times standard should be applied because of the interests in protecting attorney speech critical of judges. Under the New Y ork Times standard (New Y ork Times Co. v. Sullivan, 376 U.S. 254 (1964)), a two-part inquiry applies in determin- ing whether an attorney may be disciplined for statements criticizing a judge: (1) Whether the disciplinary authority has proven that the state- ment was a false statement of fact (or a state- ment of opinion that necessarily implies an un- disclosed false assertion of fact); and (2) assuming the statement is false, whether the attorney uttered the statement with actual mal- ice—that is, with knowledge that it was false or with reckless disregard as to its truth. In re Green, 11 P.3d 1078 (Colo. 2000). Public censure was appropriate for attor- ney who violated this rule by simultaneously representing, as defendants in a quantum meruit and lis pendens suit initiated by a subcontractor, the homeowners, the general contractor, the bank holding deed of trust on homeowners property, and two other parties who had con- tracted with contractor. Balancing the serious- ness of the misconduct with the factors in miti- gation, and taking into account the respondent’s mental state when he entered into the conflicts in representation, public censure is appropriate. People v. Fritze, 926 P.2d 574 (Colo. 1996). Public censure warranted where, although respondent did not notify his clients and op- posing counsel of his suspension, he did no- tify the court early in proceedings, did not go forward with court proceedings while on sus- pension and no actual harm was demonstrated to any of his clients. People v. Dover, 944 P.2d 80 (Colo. 1997). Stipulated agreement and recommenda- tion of public censure with certain conditions and monitoring based upon conditional ad- mission of misconduct were warranted for at- torney who required that his associates sign a covenant that hindered a client’s right to choose his or her own lawyer by interfering with the client’s right to discharge his or her lawyer at any time, with or without cause. People v. Wil- son, 953 P.2d 1292 (Colo. 1998). Public censure was appropriate where at- torney falsely testified that he had automobile insurance at the time of an accident, but out- come of case was not thereby affected. People v. Small, 962 P.2d 258 (Colo. 1998). Knowingly deceiving a client by altering a settlement check generally would warrant a 30-day suspension, however, because the client was uninjured by the deception and the respon- dent had no previous discipline in 13 years of practice, public censure was adequate. People v. Waitkus, 962 P.2d 977 (Colo. 1998). One-year and one-day suspension war- ranted where respondent failed to serve a cross-claim, failed to respond to several mo- tions, failed to keep client informed, advanced defense that was not warranted by the facts and existing law, and misrepresented to client the basis for the judgment in favor of the opposing party. People v. Genchi, 849 P.2d 28 (Colo. 1993). Six-month penalty justified for attorney pleading guilty to making and altering a false and forged prescription for a controlled sub- stance and of criminal attempt to obtain a controlled substance by forgery and altera- tion, where mitigating factors included: (1) No prior disciplinary history; (2) personal or emo- tional problems at time of misconduct; (3) full and free disclosure by attorney to grievance committee; (4) imposition of other penalties and sanctions resulting from criminal proceeding; (5) demonstration of genuine remorse; and (6) relative inexperience in the practice of law. People v. Moore, 849 P.2d 40 (Colo. 1993). Six-month suspension appropriate for re- spondent convicted of drunken driving of- fense and assault. People v. Shipman, 943 P.2d 458 (Colo. 1997); People v. Reaves, 943 P.2d 460 (Colo. 1997). Multiple criminal and traffic convictions demonstrate a pattern of misconduct, and the presence of multiple offenses warrants suspen- sion for six months with the requirement of reinstatement proceedings. People v. V an Buskirk, 962 P.2d 975 (Colo. 1998). Demonstration of four conditions required for attorney publicly censured after convic- tion of driving while ability impaired: Con- tinue psychotherapy, remain on antabuse, sub- mit monthly reports regarding progress on antabuse, and execute written authorization to therapist to release medical information regard- ing status on antabuse. People v. Rotenberg, 911 P.2d 642 (Colo. 1996). Thirty-day suspension warranted where lawyer, who represented an individual accused of first-degree murder, communicated with co- defendant who also was charged with first-de- gree murder and whose interests were adverse to the lawyer’s client, without the knowledge or consent of the co-defendant’s lawyers. The po- tential for harm was high in a first-degree mur- der case and the number of unauthorized con- tacts demonstrated more than negligence on the lawyer’s part. People v. DeLoach, 944 P.2d 522 (Colo. 1997). Stipulated agreement and recommenda- tion of suspension for 30 days based upon conditional admission of misconduct were warranted for attorney who committed unfair insurance claim settlement practices and tortious conduct in handling insurance investi- gation of fire claim that he was not competent to handle. People v. McClung, 953 P.2d 1282 (Colo. 1998). Forty-five-day suspension warranted for attorney’s professional misconduct involving the improper collection of attorney’s fees in six instances. People v. Peters, 849 P.2d 51 (Colo. 1993). Suspension of three months is appropriate when attorney engaged in sexual intercourse with dissolution of marriage client on one occa- sion, had a history of disciplinary sanctions, but cooperated with the disciplinary investigation. People v. Barr, 929 P.2d 1325 (Colo. 1996). Nine-month suspension stayed upon the requirement to pay restitution to clients is justified when violating this rule in conjunction with other disciplinary rules, particularly given the substantial and continuous incompetence, advancement of meritless claims, and signifi- cant financial harm conduct caused clients in this case. People v. Bontrager, 407 P.3d 1235 (Colo. O.P .D.J. 2017). Suspension for one year and one day, with conditional stay of all but 60 days, warranted for attorney’s backdating of brief and certificate of service, after which attorney voluntarily re- ported misconduct, attempted to rectify the vio- lation, cooperated in disciplinary proceedings, and showed genuine remorse. People v. May- nard, 219 P.3d 430 (Colo. O.P .D.J. 2008). Suspension for one year and one day ap- propriate where attorney, among other disci- plinary rule violations, violated section (d) by failing to pay attorney fees until two years after a malpractice action against the attorney and section (h) by engaging in two non-sufficient funds transactions involving his ‘‘special’’ ac- count, and twenty-two non-sufficient funds transactions in his personal account. People v. Johnson, 944 P.2d 524 (Colo. 1997). Suspension for one year and one day ap- propriate where attorney had a selfish or dis- honest motive in retaining fees he received from clients that rightfully belonged to his law firm, but had no prior disciplinary record and made a timely good faith effort to provide res- titution. People v. Bronstein, 964 P.2d 514 (Colo. 1998) (overruled in In the Matter of Thompson, 991 P.2d 820 (Colo. 1999)). Suspension for one year and one day war- ranted where attorney violated section (c) by knowingly submitting a false statement to the small business administration for the purpose of obtaining a loan. People v. Mitchell, 969 P.2d 662 (Colo. 1998). Suspension of one year and one day appro- priate where attorney committed offense of third-degree sexual assault on a client and reck- lessly accused a lawyer and judge of having an improper ex parte communication. In re Egbune, 971 P.2d 1065 (Colo. 1999). It is appropriate to condition reinstate- ment, after suspension for a year and a day, upon the attorney’s submission to an inde- pendent medical examination by a qualified psychiatrist, where the attorney’s belief in a conspiracy to remove her from the practice of law was both ingrained and illogical. The sus- pension is warranted because the attorney vio- lated section (d) by threatening to sue witnesses if they testified at a hearing over an award of attorney fees and section (c) by secretly negoti- ating with opposing litigants for additional at- torney fees when the attorney’s contingency fee contract with her former clients gave them a potentially valid claim to a portion of the fees. People v. Maynard, 275 P.3d 780 (Colo. O.P .D.J. 2010). Two-year suspension warranted when at- torney entered Alford plea to defer judgment on a charge of soliciting for child prostitution. People v. Gritchen, 908 P.2d 70 (Colo. 1995). Two-year suspension warranted when attor- ney volunteered to fulfill a teenage girl’s re- quest for alcohol and sexually assaulted her, eventually pleading guilty to unlawful sexual contact, a class-one misdemeanor. People v. Benight, 470 P.3d 1005 (Colo. O.P .D.J. 2016). Driving while under the influence of alco- hol with an expired driver’s license and no proof of insurance, and accepting one ounce of cocaine as payment for legal services from a person believed to be a client facing drug charges, warranted a three-year suspension. People v. Madrid, 967 P.2d 627 (Colo. 1998). Suspension for three years was appropri- ate in case involving violation of this rule and others, together with attorney’s breach of his duty as client’s trustee to protect his client, who was a particularly vulnerable victim that was recuperating from a serious head injury. People v. DeRose, 945 P.2d 412 (Colo. 1997). Suspension of three years was appropriate for attorney who drove a vehicle on at least four occasions after his driver’s license was revoked and who also failed to appear in two cases involving his illegal driving. People v. Hughes, 966 P.2d 1055 (Colo. 1998). Suspension for three years appropriate when attorney circumvented proper channels for the adoption of a child by falsely listing her own husband as the birth father on the baby’s birth certificate, counseled her husband to en- gage in fraudulent conduct, and provided false information on a petition for stepparent adop- tion. People v. Ritland, 327 P.3d 914 (Colo. O.P .D.J. 2014). Suspension for three years appropriate for attorney who repeatedly violated a protection order, committed a physical assault, and carried out a retributive campaign of emotional harass- ment against a vulnerable victim. People v. Saxon, 470 P.3d 927 (Colo. O.P .D.J. 2016). Suspension for one year and one day war- ranted where attorney failed to appear in county court on a charge of driving under the influence. People v. Myers, 969 P.2d 701 (Colo. 1998). A long period of suspension, rather than disbarment, is warranted when acts com- plained of occurred before an earlier disciplin- ary action against the attorney and mitigating factors exist. Attorney’s actions were more properly viewed as a pattern of misconduct. In re V an Buskirk, 981 P.2d 607 (Colo. 1999). Thirty-day suspension appropriate where attorney overdrew his Colorado Lawyer Trust Account Foundation (COLTAF) account but shortly thereafter deposited sufficient funds to cure the deficiency, negligently failed to keep adequate trust account records, knowingly and repeatedly failed to respond to several requests for information from the office of attorney regu- lation counsel, eventually provided bank re- cords that revealed no further misconduct on his part, and faced a number of challenges in his personal life at the time he knowingly failed to cooperate with the office of attorney regulation counsel. People v. Edwards, 201 P.3d 555 (Colo. 2008). Behavior toward client that precipitated conflict on day of client’s criminal trial, forcing client’s newly appointed public defender to seek a continuance to have adequate time to prepare violates this rule. People v. Brenner, 852 P.2d 456 (Colo. 1993). Pushing another attorney in the court- room, resulting in a conviction for third-degree assault, warranted a 30-day suspension. People v. Nelson, 941 P.2d 922 (Colo. 1997). Lawyer who imposed unauthorized charg- ing lien and subsequently failed to release such lien, and who testified at grievance pro- ceedings that he kept documents belonging to third parties in order to protect his client’s fi- nancial interests, which was the first instance at which such a theory was raised, violated this rule. Although the attorney’s motives were dis- honest and selfish, the grievance against the attorney involved in multiple offenses, the attor- ney violated a disciplinary rule at the grievance proceedings, and the attorney failed to acknowl- edge wrongful nature of his conduct, the miti- gating factors included the fact that the attorney had not been subject to prior grievances and the attorney was relatively inexperienced. Thus, the appropriate sanction is public censure. People v. Brown, 840 P.2d 1085 (Colo. 1992). In determining appropriate sanction, it is not important whether injured party was at- torney’s client, when attorney-respondent was appointed conservator. People v. Vigil, 929 P.2d 1311 (Colo. 1996). Conduct warranted one-year extension of attorney’s suspension. People v. Silvola, 933 P.2d 1308 (Colo. 1997). Disbarment warranted for respondent who continued to practice law while under suspension. Respondent was suspended based upon conviction for possession of cocaine, a class 3 felony, and upon release from prison represented to several persons that he was a licensed attorney and provided legal services to those persons. Board’s finding that respondent had a history of prior discipline, a dishonest or selfish motive, displayed a pattern of miscon- duct, had committed multiple offenses, had en- gaged in a bad faith obstruction of the disciplin- ary process, had refused to acknowledge any wrongful conduct on his part, had substantial experience in law, and could offer no mitigating factors warranted disbarment. People v. Stauffer, 858 P.2d 694 (Colo. 1993). Disbarment warranted for respondent convicted of repeated theft from her immi- gration clients. People v. Cohen, 369 P.3d 289 (Colo. O.P .D.J. 2016). Disbarment appropriate remedy where at- torney neglected a legal matter, misappropriated funds and property, abandoned client, engaged in fraud, evaded process, and failed to cooper- ate in disciplinary investigation. People v. Hindman, 958 P.2d 463 (Colo. 1998). Disbarment is the presumed sanction for knowing misappropriation of funds from cli- ents or one’s law firm, barring significant miti- gating circumstances. People v. Guyerson, 898 P.2d 1062 (Colo. 1995); People v. V arallo, 913 P.2d 1 (Colo. 1996); In the Matter of Thomp- son, 991 P.2d 820 (Colo. 1999) (overruling People v. Bronstein, 964 P.2d 514 (Colo. 1998)); People v. Sweetman, 218 P.3d 1123 (Colo. O.P .D.J. 2008); People v. Fiore, 301 P.3d 1250 (Colo. O.P .D.J. 2013). Disbarment appropriate when attorney ac- cepted legal fees, performed limited services, abandoned the client, and then misappropri- ated the unearned fees. People v. Kuntz, 942 P.2d 1206 (Colo. 1997); People v. Ross, 350 P.3d 327 (Colo. O.P .D.J. 2015). Aiding client to violate custody order suf- ficient to justify disbarment. People v. Chappell, 927 P.2d 829 (Colo. 1996). Structuring financial transaction to enable client to avoid reporting requirements, a felony under federal law, warranted disbarment. In re DeRose, 55 P.3d 126 (Colo. 2002). Conduct violating this rule sufficient to justify disbarment where attorney continued to practice law when under suspension. People v. Redman, 902 P.2d 839 (Colo. 1995). One-year and one-day suspension plus payment of restitution and costs proper for attorney who induced a loan through misrepre- sentations, assigned a promissory note obtained with proceeds of such loan without lender’s knowledge or consent, and misrepresented that sufficient funds were in trust account to cover check. People v. Kearns, 843 P.2d 1 (Colo. 1992). False statements by attorney in connection with an accident in which the attorney was at fault adversely reflects on attorney’s fitness to practice law. People v. Dieters, 935 P.2d 1 (Colo. 1997). Pleading guilty to a single count of bank fraud evidences serious criminal conduct warranting disbarment. People v. Terborg, 848 P.2d 346 (Colo. 1993); People v. Borzillo, 464 P.3d 281 (Colo. O.P .D.J. 2016). Pleading guilty to felony theft evidences serious criminal conduct warranting disbar- ment. People v. Larson, 318 P.3d 89 (Colo. O.P .D.J. 2013). Pleading guilty to felony theft from at-risk victims is a crime of dishonesty that war- rants disbarment. People v. Zarlengo, 367 P.3d 1197 (Colo. O.P .D.J. 2016). Attorney’s repeated assurances to client that he would file a motion for reconsideration, his failure to do so, and his neglect of a legal matter entrusted to him constitute disciplinary violations warranting suspension for 30 days where there are mitigating factors. People v. LaSalle, 848 P.2d 348 (Colo. 1993). Attorney’s neglect resulting in an untimely filing of an inadequate certificate of review and dismissal of his client’s case, combined with fact that certificate contained false statements of material fact that attorney later repeated to an investigative counsel with the office of disciplinary counsel, consti- tuted disciplinary violations warranting a 45- day suspension, despite mitigating factors. People v. Porter, 980 P.2d 536 (Colo. 1999). Ninety-day suspension justified where at- torney’s failure to respond to discovery re- quests resulted in default and entry of judg- ment against client for $816,613. People v. Clark, 927 P.2d 838 (Colo. 1996). Ninety-day suspension and order of resti- tution as a condition of reinstatement was justified where attorney failed to pay court-or- dered award of attorney’s fees resulting from his filing of a frivolous motion and then failed to appear at a deposition. People v. Huntzinger, 967 P.2d 160 (Colo. 1998). Thirty-day suspension appropriate where attorney failed to inform U.S. bankruptcy court in Colorado, in a hearing on a motion to remand the matter to U.S. bankruptcy court in Massachusetts, that an order of dismissal of the bankruptcy proceeding between the same par- ties had been entered in California. People v. Farry, 927 P.2d 841 (Colo. 1996). Suspension stayed, in view of respondent’s cooperation and remorse, conditioned upon suc- cessful completion of six-month probationary period and ethics refresher course. People v. Rosen, 199 P.3d 1241 (Colo. O.P .D.J. 2007). Three-month suspension, stayed pending successful completion of an 18-month proba- tionary period including cultural sensitivity training, was appropriate for respondent who violated section (g) by referring to judge in bigoted terms during private e-mail exchange with client. People v. Abrams, 459 P.3d 1228 (Colo. O.P .D.J. 2020), aff’d, 2021 CO 44, 488 P.3d 1043. Lawyer advertisement containing false, misleading, deceptive, or unfair statements violates this rule and warrants public cen- sure where respondent terminated referral ser- vice being advertised after the initial request for investigation was filed and cooperated in disci- plinary proceedings but had received a past let- ter of admonition and had substantial experi- ence in the practice of law. People v. Carpenter, 893 P.2d 777 (Colo. 1995). Public censure appropriate where attorney misrepresented the status of a dismissed case to his client, the resultant actual harm to the client was only the cost of hiring a new lawyer to pursue an appeal of the dismissal, the attorney’s law firm reimbursed the client for all fees it had collected, the attorney reimbursed the firm for such fees, the only aggravating factor was a 1994 letter of admonition given to the attorney for improperly communicating with a repre- sented person, and mitigating factors included the absence of a dishonest or selfish motive, remorse, and full and free disclosure in the disciplinary proceedings. People v. Johnston, 955 P.2d 1051 (Colo. 1998). Public censure appropriate where harm suffered by attorney’s client was speculative, attorney retracted his misrepresentations and admitted to his client before the institution of disciplinary proceedings that he had done noth- ing on the client’s appeal, attorney had no prior discipline, he made full and free disclosure of his misconduct to the grievance committee, and he expressed remorse for his misconduct. People v. Nelson, 848 P.2d 351 (Colo. 1993). Public censure appropriate where attorney neglected and made misrepresentations in two separate legal matters. People v. Eagan, 902 P.2d 841 (Colo. 1995). Public censure appropriate in light of miti- gating circumstances for possession of cocaine in violation of state and federal controlled sub- stance laws. People v. Gould, 912 P.2d 556 (Colo. 1996). Public censure appropriate where respon- dent was convicted of driving while ability im- paired and had also appeared in court while intoxicated on two consecutive days. People v. Coulter, 950 P.2d 176 (Colo. 1998). Public censure appropriate for attorney who had been reprimanded in Connecticut for failure to file federal income tax return and attorney had not been disciplined before in Colorado. People v. Perkell, 969 P.2d 703 (Colo. 1998). Public censure was warranted where attor- ney twice requested arresting officers in driv- ing under the influence cases not to appear at license revocation hearings before the depart- ment of motor vehicles. People v. Carey, 938 P.2d 1166 (Colo. 1997). Public censure was appropriate where sig- nificant mitigating factors were present. At- torney was convicted of vehicular assault, a class 4 felony, and two counts of driving under the influence of alcohol. The crimes are strict liability offenses for which attorney must serve three years in the custody of the department of corrections, followed by a two-year mandatory period of parole. Section 18-1-105(3) provides that, while he is serving his sentence, attorney is disqualified from practicing as an attorney in any state courts. The sentence and disqualifica- tion from practicing law are a significant ‘‘other penalty[] or sanction[]’’ and therefore a mitigat- ing factor in determining the level of discipline. In re Kearns, 991 P.2d 824 (Colo. 1999) (de- cided under former C.R.C.P. 241.6(5)). Public censure is appropriate for driving under the influence with mitigating factor of candidness and cooperativeness. This was at- torney’s first conviction, and he was truthful, candid, and cooperative. He also underwent al- cohol evaluation by a doctor. People v. Miller, 409 P.3d 667 (Colo. O.P .D.J. 2017). Public censure was warranted for attorney who prepared motions to dismiss for his client’s wife to sign when proceedings had been brought by the client’s wife against the client and the client’s wife was represented by coun- sel and was not advised that she should contact her own lawyer before signing the motions, nor asked if she wished to discuss the motions with her lawyer before signing. Three letters of ad- monition for unrelated misconduct also were an aggravating factor for purposes of determining the appropriate level of discipline. People v. McCray, 926 P.2d 578 (Colo. 1996). Public censure warranted for attorney’s solicitation of prostitution during telephone call with wife of client whom he was represent- ing in a dissolution of marriage proceeding. People v. Bauder, 941 P.2d 282 (Colo. 1997). Public censure was warranted where attor- ney made inappropriate, harmful, offensive, harassing, and sexually abusive comments to potential client. The mitigating factors found by the hearing board do not compel a different result. People v. Meier, 954 P.2d 1068 (Colo. 1998). Chief deputy district attorney’s theft of less than $50 constitutes conduct warranting public censure where significant mitigating fac- tors exist. People v. Buckley, 848 P.2d 353 (Colo. 1993). Two-year suspension was an adequate sanction where attorney neglected client mat- ters by representing that he would file a lawsuit and neglected to do so, engaged in conduct involving dishonesty, fraud, deceit, or misrepre- sentation by agreeing to represent client and thereafter failing to advise the client of attor- ney’s suspension, and where attorney further engaged in misrepresentation by collecting le- gal fees and costs from client while attorney was under suspension. People v. de Baca, 948 P.2d 1 (Colo. 1997). Transferring various ownership interests to lawyer employees of firm who did not receive profits and were not managers war- ranted suspension of one year and a day. Suspension appropriate because attorney made misrepresentations and was dishonest in such transfers. People v. Reed, 942 P.2d 1204 (Colo. 1997). Thirty-day suspension was appropriate discipline where attorney advised client to take action in violation of child custody order but failed to warn her of criminal consequences of such action. People v. Aron, 962 P.2d 261 (Colo. 1998). Suspension of eight months appropriate for attorney who assaulted his wife in their marital home and denied any wrongdoing. People v. Betterton-Fike, 479 P.3d 436 (Colo. O.P .D.J. 2020). Depositing personal funds into a COLTAF account to hide personal assets from credi- tors supports a 90-day suspension with con- ditions of reinstatement. People v. Alster, 221 P.3d 1088 (Colo. O.P .D.J. 2009). Nine-month suspension appropriate where respondent committed domestic violence, has not been fully candid, and has not given the hearing board any confidence that his miscon- duct will not recur. People v. Falco, 470 P.3d 688 (Colo. O.P .D.J. 2016). Suspension of one year and one day was appropriate based on evidence of three sepa- rate incidents in which the attorney physi- cally assaulted his girlfriend. It was immate- rial that no charges had been filed in any of the incidents, because the acts alone reflected ad- versely on the attorney’s fitness to practice law. The fact that the attorney’s behavior was not directly related to his practice of law was a factor to be considered, but was not conclusive. The attorney had failed to take any steps toward rehabilitation following the incidents, and the three separate assaults showed a pattern of mis- conduct. Therefore, it was appropriate to sus- pend the attorney and require him to demon- strate rehabilitation and completion of a certified domestic violence treatment program as a condition of reinstatement. People v. Musick, 960 P.2d 89 (Colo. 1998). Disorderly conduct involving a domestic dispute contravenes subsection (b) of this rule and warrants discipline. People v. Olson, 470 P.3d 789 (Colo. O.P .D.J. 2016). Attorney conduct violating this rule, in conjunction with other rules, sufficient to justify suspension when violation did not arise from neglect or willingness to take advantage of client’s vulnerability and is mitigated by her inexperience in the practice of law, her lack of any prior disciplinary record, the fact that she had already been held in contempt and punished by the district court, and the fact that there is no suggestion of selfish motivation. Attorney’s failure to appreciate the serious nature of con- duct and the jurisdiction of the hearing board to discipline her is a serious matter meriting a period of suspension and a redetermination of her fitness before being permitted to practice law again. In re Roose, 69 P.3d 43 (Colo.), cert. denied, 540 U.S. 1053 (2003). Suspension for three years, rather than disbarment, was appropriate where violation of this rule and others caused serious harm to attorney’s clients, but mitigating factors were present, including no previous discipline in 14 years of practice, personal and emotional prob- lems, and cooperation and demonstrated re- morse in proceedings. People v. Henderson, 967 P.2d 1038 (Colo. 1998). Conduct violating this rule in conjunction with other disciplinary rules, where mitigat- ing factors were present, warrants public censure. People v. Davis, 950 P.2d 596 (Colo. 1998). Conduct violating this rule in conjunction with other disciplinary rules is sufficient to justify suspension, stayed upon completion of one-year period of probation with conditions. People v. Bendinelli, 329 P.3d 300 (Colo. O.P .D.J. 2014). Conduct violating this rule in conjunction with other disciplinary rules is sufficient to justify suspension for nine months plus addi- tional conditions. People v. Muhr, 370 P.3d 667 (Colo. O.P .D.J. 2015). Pleading guilty to one count of bribery evidences conduct warranting disbarment. People v. Viar, 848 P.2d 934 (Colo. 1993). Disbarment is warranted where attorney was convicted of felony offense of forging a federal bankruptcy judge’s signature and had engaged in multiple types of other dishonest conduct and where there was an insufficient showing of mental disability. People v. Goldstein, 887 P.2d 634 (Colo. 1994). Disbarment is the only condign sanction for attempted second degree murder. Respon- dent nearly killed his wife by brutally attacking her with a hatchet and a kitchen knife. People v. Kintzele, 409 P.3d 680 (Colo. O.P .D.J. 2017). Disbarment is warranted where attorney was convicted in Hawaii of second-degree murder. People v. Draizen, 941 P.2d 280 (Colo. 1997). Disbarment appropriate sanction for at- torney who intentionally killed another per- son. Despite a lack of prior discipline in this state, giving full faith and credit to another state’s law and its jury finding that attorney intentionally took her husband’s life by shoot- ing him 10 times with a firearm, disbarment is an appropriate sanction. People v. Sims, 190 P.3d 188 (Colo. O.P .D.J. 2008). Disbarment is warranted for attorney con- victed of one count of sexual assault on a child, notwithstanding lack of a prior record of discipline. People v. Espe, 967 P.2d 159 (Colo. 1998). Disbarment was appropriate, despite exis- tence of mitigating factors, where attorney violated section (c) of this rule by misappro- priating bar association funds for his personal use and where such misappropriation was knowing. People v. Motsenbocker, 926 P.2d 576 (Colo. 1996). Disbarment was appropriate for knowing misappropriation of funds despite fact respon- dent had not been previously disciplined. People v. Dice, 947 P.2d 339 (Colo. 1997). Disbarment is appropriate when a lawyer knowingly misappropriates client funds in the absence of extraordinary mitigating factors. Mitigating factors such as stress due to pro- longed divorce, personal financial losses, a se- rious motor vehicle accident, filing for bank- ruptcy, a deteriorating law practice, and alcohol abuse were insufficient to deviate from the rule that a clear and convincing showing of a know- ing misappropriation of client funds warrants disbarment. People v. Torpy, 966 P.2d 1040 (Colo. 1998). Disbarment is warranted where attorney knowingly converted funds belonging to law firm and where attorney knowingly acted dis- honestly toward the firm and the disciplinary board investigator. People v. Bardulis, 203 P.3d 632 (Colo. O.P .D.J. 2009). Disbarment is only appropriate remedy for knowingly misappropriating client funds, unless significant extenuating circumstances are pres- ent. In re Cleland, 2 P.3d 700 (Colo. 2000). Disbarment is warranted where attorney converted client’s funds in multiple collec- tions cases and committed other rule viola- tions, thus causing severe injury to the client. People v. Solomon, 301 P.3d 1244 (Colo. O.P .D.J. 2013). Disbarment warranted for knowingly abandoning clients, converting their funds, and causing actual financial and emotional harm to them. Attorney violated duty to pre- serve clients’ property, to diligently perform services on their behalf, to be candid with them during the course of the professional relation- ship, and to abide by the legal rules of sub- stance and procedure that affect the administra- tion of justice. People v. Martin, 223 P.3d 728 (Colo. O.P .D.J. 2009). Disbarment warranted for attorney con- victed of conspiracy to commit tax fraud, tax evasion, and aiding and assisting in the preparation of a false income tax return. People v. Evanson, 223 P.3d 735 (Colo. O.P .D.J. 2009). Disbarment warranted for knowingly par- ticipating in a long-running tax evasion scheme, actively assisting more than 150 cli- ents to disobey their legal obligations by collec- tively defrauding the federal government of millions of dollars. People v. Sugar, 360 P.3d 1041 (Colo. O.P .D.J. 2015). Attorney conduct violating this rule, in conjunction with other rules, sufficient to justify disbarment when attorney knowingly commingled and misappropriated clients’ funds for his personal use, neglected filing a com- plaint in a case until it was barred by the statute of limitations, failed to comply with court or- ders applicable to his child support payments, and neglected two other cases causing default judgments to be entered against his client, de- spite fact that one of the judgments was subse- quently set aside. People v. Gonzalez, 967 P.2d 156 (Colo. 1998). Attorney who was the trustee of client’s trust violated section (h) by utilizing the trust’s funds to loan money to his daughter and to purchase his son-in-law’s parents’ former resi- dence for the purpose of leasing it back to them, and by then failing to take any legal action against them when they did not make lease payments. People v. DeRose, 945 P.2d 412 (Colo. 1997). Previously disbarred attorney who violated this rule would be forced to pay restitution to clients as a condition of readmission. People v. Vigil, 945 P.2d 1385 (Colo. 1997). Prior discipline for conduct violating this rule is an important factor in determining the proper level of discipline, therefore disbar- ment is merited where attorney continues to engage in misconduct. In re C de Baca, 11 P.3d 426 (Colo. 2000). Court erred when it ordered special advo- cate to refund fees without determining whether conduct violated section (c). In re Redmond, 131 P.3d 1167 (Colo. App. 2005). Conduct violating this rule, in conjunction with other disciplinary rules, sufficient to justify disbarment where the attorney contin- ued to practice law while on suspension, repeat- edly neglecting his clients and failing to take reasonable steps to protect clients’ interests. People v. Fager, 938 P.2d 138 (Colo. 1997). Conduct found to violate disciplinary rules. People v. Brenner, 852 P.2d 452 (Colo. 1993). Attorney who knowingly violated rule but without intent to deceive court is justifiably sanctioned. People v. Trogani, 203 P.3d 643 (Colo. O.P .D.J. 2008). Conduct violating this rule in conjunction with other disciplinary rules is sufficient to justify public censure. People v. Doherty, 908 P.2d 1120 (Colo. 1996); People v. Woodrum, 911 P.2d 640 (Colo. 1996); People v. Pooley, 917 P.2d 712 (Colo. 1996); People v. Newman, 925 P.2d 783 (Colo. 1996); People v. Y ates, 952 P.2d 340 (Colo. 1998); People v. Barr, 957 P.2d 1379 (Colo. 1998); People v. Rolfe, 962 P.2d 981 (Colo. 1998); Matter of Olsen, 2014 CO 42, 326 P.3d 1004. Conduct violating this rule sufficient to justify public censure. People v. Gonzalez, 933 P.2d 1306 (Colo. 1997); People v. Meier, 954 P.2d 1068 (Colo. 1998); In re Wilson, 982 P.2d 840 (Colo. 1999). Conduct violating this rule in conjunction with other disciplinary rules is sufficient to justify suspension. People v. Barr, 855 P.2d 1386 (Colo. 1993); People v. Crews, 901 P.2d 472 (Colo. 1995); People v. Kuntz, 908 P.2d 1110 (Colo. 1996); People v. Sigley, 917 P.2d 1253 (Colo. 1996); People v. McCaffrey, 925 P.2d 269 (Colo. 1996); People v. Fager, 925 P.2d 280 (Colo. 1996); People v. Hohertz, 926 P.2d 560 (Colo. 1996); People v. Bates, 930 P.2d 600 (Colo. 1997); People v. Reynolds, 933 P.2d 1295 (Colo. 1997); People v. White, 935 P.2d 20 (Colo. 1997); People v. McGuire, 935 P.2d 22 (Colo. 1997); People v. Mason, 938 P.2d 133 (Colo. 1997); People v. Kotarek, 941 P.2d 925 (Colo. 1997); People v. Primavera, 942 P.2d 496 (Colo. 1997); People v. Field, 944 P.2d 1252 (Colo. 1997); People v. Wotan, 944 P.2d 1257 (Colo. 1997); People v. Johnson, 946 P.2d 469 (Colo. 1997); People v. Barnthouse, 948 P.2d 534 (Colo. 1997); People v. Blunt, 952 P.2d 356 (Colo. 1998); People v. Easley, 956 P.2d 1257 (Colo. 1998); People v. Hanks, 967 P.2d 144 (Colo. 1998); People v. Harding, 967 P.2d 153 (Colo. 1998); In re Nangle, 973 P.2d 1271 (Colo. 1999); In re Corbin, 973 P.2d 1273 (Colo. 1999); In re Bobbitt, 980 P.2d 538 (Colo. 1999); In re Meyers, 981 P.2d 143 (Colo. 1999); In re Demaray, 8 P.3d 427 (Colo. 1999); In re Hickox, 57 P.3d 403 (Colo. 2002); In re Fischer, 89 P.3d 817 (Colo. 2004); People v. Rosen, 199 P.3d 1241 (Colo. O.P .D.J. 2007); People v. Beecher, 224 P.3d 442 (Colo. O.P .D.J. 2009); People v. Maynard, 238 P.3d 672 (Colo. O.P .D.J. 2009); People v. Brennan, 240 P.3d 887 (Colo. O.P .D.J. 2009); People v. Albani, 276 P.3d 64 (Colo. O.P .D.J. 2011); People v. Culter, 277 P.3d 954 (Colo. O.P .D.J. 2011); People v. Duggan, 282 P.3d 534 (Colo. O.P .D.J. 2012); People v. Staab, 287 P.3d 122 (Colo. O.P .D.J. 2012); People v. V erce, 286 P.3d 1107 (Colo. O.P .D.J. 2012); People v. Cochrane, 296 P.3d 1051 (Colo. O.P .D.J. 2013); People v. Head, 332 P.3d 117 (Colo. O.P .D.J. 2013). People v. Beecher, 350 P.3d 310 (Colo. O.P .D.J. 2015); People v. Miller, 354 P.3d 1136 (Colo. O.P .D.J. 2015). People v. Quigley, 359 P.3d 1045 (Colo. O.P .D.J. 2015); People v. Hill, 439 P.3d 1244 (Colo. O.P .D.J. 2019); People v. Romero, 452 P.3d 275 (Colo. O.P .D.J. 2019); People v. Hyde, 470 P.3d 772 (Colo. O.P .D.J. 2016); People v. Lindquist, 470 P.3d 961 (Colo. O.P .D.J. 2016); People v. Sanders, 470 P.3d 978 (Colo. O.P .D.J. 2016); People v. Morris, 470 P.3d 988 (Colo. O.P .D.J. 2016); People v. Condon, 470 P.3d 1025 (Colo. O.P .D.J. 2016); People v. Spurlock, 470 P.3d 712 (Colo. O.P .D.J. 2017); People v. Braham, 470 P.3d 1031 (Colo. O.P .D.J. 2017); People v. Layton, 494 P.3d 693 (Colo. O.P .D.J. 2021); People v. Raines, 510 P.3d 1089 (Colo. O.P .D.J. 2022). Conduct violating this rule sufficient to justify suspension. People v. Farrant, 852 P.2d 452 (Colo. 1993); People v. Graham, 933 P.2d 1321 (Colo. 1997); People v. Dieters, 935 P.2d 1 (Colo. 1997); People v. Rudman, 948 P.2d 1022 (Colo. 1997); In re V an Buskirk, 981 P.2d 607 (Colo. 1999); In re Sather, 3 P.3d 403 (Colo. 2000); People v. Trogani, 203 P.3d 643 (Colo. O.P .D.J. 2008); People v. Steinman, 452 P.3d 240 (Colo. O.P .D.J. 2019); People v. Qin, 470 P.3d 863 (Colo. O.P .D.J. 2016); People v. Lewis, 522 P.3d 750 (Colo. O.P .D.J. 2022). Conduct violating this rule in conjunction with other disciplinary rules is sufficient to justify disbarment. People v. Kelley, 840 P.2d 1068 (Colo. 1992); People v. Walsh, 880 P.2d 766 (Colo. 1994); People v. Marsh, 908 P.2d 1115 (Colo. 1996); People v. Jenks, 910 P.2d 688 (Colo. 1996); People v. Jamrozek, 921 P.2d 725 (Colo. 1996); People v. Ebbert, 925 P.2d 274 (Colo. 1996); People v. Steinman, 930 P.2d 596 (Colo. 1997); People v. Wallace, 936 P.2d 1282 (Colo. 1997); People v. Mannix, 936 P.2d 1285 (Colo. 1997); People v. Madigan, 938 P.2d 1162 (Colo. 1997); People v. Odom, 941 P.2d 919 (Colo. 1997); People v. McDowell, 942 P.2d 486 (Colo. 1997); People v. Sousa, 943 P.2d 448 (Colo. 1997); People v. Jackson, 943 P.2d 450 (Colo. 1997); People v. Schaefer, 944 P.2d 78 (Colo. 1997); People v. Clyne, 945 P.2d 1386 (Colo. 1997); People v. Crist, 948 P.2d 1020 (Colo. 1997); People v. Roybal, 949 P.2d 993 (Colo. 1997); People v. Holmes, 951 P.2d 477 (Colo. 1998); People v. Singer, 955 P.2d 1005 (Colo. 1998); People v. Holmes, 955 P.2d 1012 (Colo. 1998); People v. V alley, 960 P.2d 141 (Colo. 1998); People v. Skaalerud, 963 P.2d 341 (Colo. 1998); In re Bilderback, 971 P.2d 1061 (Colo. 1999); In re Hugen, 973 P.2d 1267 (Colo. 1999); In re Tolley, 975 P.2d 1115 (Colo. 1999); In re Lopez, 980 P.2d 983 (Colo. 1999); In re Haines, 177 P.3d 1239 (Colo. 2008); People v. Rasure, 212 P.3d 973 (Colo. O.P .D.J. 2009); People v. Sweetman, 218 P.3d 1123 (Colo. O.P .D.J. 2008); People v. Gallegos, 229 P.3d 306 (Colo. O.P .D.J. 2010); People v. Ed- wards, 240 P.3d 1287 (Colo. O.P .D.J. 2010); People v. Zodrow, 276 P.3d 113 (Colo. O.P .D.J. 2011); People v. Rozan, 277 P.3d 942 (Colo. O.P .D.J. 2011); People v. Calvert, 280 P.3d 1269 (Colo. O.P .D.J. 2011); People v. Alexan- der, 281 P.3d 496 (Colo. O.P .D.J. 2012); People v. Tolentino, 285 P.3d 340 (Colo. O.P .D.J. 2012); People v. Ringler, 309 P.3d 959 (Colo. O.P .D.J. 2013); People v. McNamara, 311 P.3d 622 (Colo. O.P .D.J. 2013); People v. Goodman, 334 P.3d 241 (Colo. O.P .D.J. 2014); People v. Lindley, 349 P.3d 304 (Colo. O.P .D.J. 2015); People v. Palmer, 349 P.3d 312 (Colo. O.P .D.J. 2015); People v. Doherty, 354 P.3d 1150 (Colo. O.P .D.J. 2015); People v. Kanwal, 357 P.3d 1236-1246 (Colo. O.P .D.J. 2015); People v. Weatherford, 357 P.3d 1251 (Colo. O.P .D.J. 2015); People v. Carrigan, 358 P.3d 650 (Colo. O.P .D.J. 2015); People v. Kleinsmith, 407 P.3d 1229 (Colo. O.P .D.J. 2016); People v. Waters, 438 P.3d 753 (Colo. O.P .D.J. 2019); People v. Halling, 452 P.3d 203 (Colo. O.P .D.J. 2019); People v. Walls, 452 P.3d 212 (Colo. O.P .D.J. 2019); People v. Sherer, 452 P.3d 218 (Colo. O.P .D.J. 2019); People v. Pruit, 452 P.3d 259 (Colo. O.P .D.J. 2019); People v. Dalmy, 452 P.3d 265 (Colo. O.P .D.J. 2019); People v. Heaphy, 470 P.3d 728 (Colo. O.P .D.J. 2015); People v. Williamson, 470 P.3d 745 (Colo. O.P .D.J. 2016); People v. Topper, 470 P.3d 821 (Colo. O.P .D.J. 2016); People v. Zimmerman, 470 P.3d 827 (Colo. O.P .D.J. 2016); People v. Keil, 470 P.3d 872 (Colo. O.P .D.J. 2016); People v. Adams, 470 P.3d 952 (Colo. O.P .D.J. 2016); People v. Carlson, 470 P.3d 1016 (Colo. O.P .D.J. 2016); People v. Breuer, 470 P.3d 706 (Colo. O.P .D.J. 2017); People v. Fling, 470 P.3d 720 (Colo. O.P .D.J. 2017); People v. Ward, 470 P.3d 1053 (Colo. O.P .D.J. 2017); People v. Beale, 470 P.3d 1070 (Colo. O.P .D.J. 2017); People v. Sarpong, 470 P.3d 1075 (Colo. O.P .D.J. 2017); People v. Atencio, 470 P.3d 1091 (Colo. O.P .D.J. 2017); People v. Heupel, 470 P.3d 1101 (Colo. O.P .D.J. 2017); People v. Fillerup, 520 P.3d 211 (Colo. O.P .D.J. 2022). Conduct violating this rule sufficient to justify disbarment. People v. Kelly, 840 P.2d 1068 (Colo. 1992); People v. Townshend, 933 P.2d 1327 (Colo. 1997); People v. Sichta, 948 P.2d 1018 (Colo. 1997); People v. Nearen, 952 P.2d 371 (Colo. 1998); People v. Nitschke, 350 P.3d 334 (Colo. O.P .D.J. 2015).