Public Trust, Prosecutorial Status, and Personal Dishonesty: The 60‑Day Suspension of County Attorney Naomi R. Leisz

I. Introduction

The Montana Supreme Court’s December 23, 2025 Order of Discipline in In the Matter of Naomi R. Leisz (PR 25‑0150) is a significant attorney-disciplinary decision at the intersection of:

• Personal criminal conduct by a lawyer involving dishonesty (false insurance claim and obstruction of justice);
• The heightened expectations placed on an elected prosecutor (a county attorney);
• The operation of Montana’s disciplinary framework—particularly conditional admissions under Rule 26 of the Montana Rules for Lawyer Disciplinary Enforcement (MRLDE) and Rule 8.4 of the Montana Rules of Professional Conduct (M.R. Pro. Cond.); and
• The treatment of aggravating and mitigating factors, including self-reporting and voluntary cessation of practice.

The central question in the case was not whether misconduct occurred—Naomi R. Leisz admitted the material facts and that she violated Rule 8.4—but what level of professional discipline is necessary to protect the public and preserve confidence in the legal profession, especially given that she was serving as Sanders County Attorney at the time of the events.

This commentary analyzes the decision, explains the legal framework used by the Court, and highlights the broader implications for attorney discipline—particularly for prosecutors and lawyers whose “private” misconduct involves dishonesty.

II. Summary of the Opinion

A. Factual Background

The material facts, as admitted by Leisz in her conditional admission and affidavit of consent, are straightforward but serious:

• April 2022 Accident: Leisz’s minor son was involved in a motor vehicle accident in which he struck a power pole. He did not report the accident.
• False Insurance Claim: Subsequently, Leisz submitted an insurance claim falsely stating that she was driving the vehicle at the time of the accident.
• Insurance Payment: The insurer paid the claim. A later investigation revealed that the insurer would not have paid had it known the true circumstances (i.e., that the insured lied).
• Coverage Point: Although the insurer did not seek reimbursement, Leisz noted that her son was also insured under the policy and she assumed the accident would have been covered regardless. The Court, however, treats the dishonesty—not the ultimate coverage question—as central.

Once it became clear that criminal charges were forthcoming:

• On June 30, 2023, Leisz resigned as Sanders County Attorney.
• She self-reported the impending criminal charges to the Office of Disciplinary Counsel (ODC).
• She advised ODC she was “going inactive” effective July 3, 2023, but she did not complete the State Bar’s formal process to place her license on inactive status.
• She asserts that from July 3, 2023 until her criminal case concluded, she did not practice law because she believed ODC would soon suspend her; she resumed practice when no disciplinary action had yet been taken by the time the criminal case ended.

Criminally:

• In July 2023, she was charged with Criminal Insurance Fraud (a felony).
• On April 18, 2024, she entered a plea agreement and pled guilty to Obstructing Justice (a misdemeanor).
• On April 25, 2024, the Sanders County District Court sentenced her to six months in jail (fully suspended), plus fines, fees, community service, and restitution of $3,293.00 to Northern Lights, Inc., for damage to the power pole.

B. Disciplinary Proceedings

On February 20, 2025, ODC filed a formal disciplinary complaint with the Commission on Practice (the “Commission”).

The procedural path proceeded as follows:

1. First conditional admission (April 1, 2025): Leisz initially tendered a conditional admission and affidavit of consent under MRLDE 26(B)(3). The Commission did not accept the initial disciplinary terms.
2. Second conditional admission (September 25, 2025): She submitted a revised conditional admission, again under Rule 26(B)(3), expressly:
   • Acknowledging the material facts of the complaint as true;
   • Admitting violation of M. R. Pro. Cond. 8.4 (professional misconduct); and
   • Agreeing to a specific sanction: a 60‑day suspension, payment of costs, and compliance with MRLDE 29 and 30 (notice obligations).
3. ODC concurrence: The ODC concurred in the revised conditional admission and the proposed discipline.
4. Commission hearing (October 15, 2025): The Commission held a hearing:
   • Chief Disciplinary Counsel Pam Bucy advocated acceptance of the conditional admission and the agreed-upon 60‑day suspension.
   • She disclosed that:
     • Leisz had been previously disciplined in 2006.
     • ODC and Leisz initially agreed on a 30‑day suspension, but the Commission indicated that would be too lenient; they later agreed to 60 days.
   • Leisz’s counsel Nick Brooke emphasized that she voluntarily ceased practice for about 14 months, despite not formally changing to inactive status.
5. Commission’s recommendation (October 30, 2025): The Commission issued Findings of Fact, Conclusions of Law, and a Recommendation for Discipline, advising the Supreme Court to:
   • Accept the conditional admission;
   • Impose a 60‑day suspension from practice;
   • Require payment of costs; and
   • Require compliance with MRLDE 29 and 30.

The Commission stressed that anything less than a 60‑day suspension would “erode public confidence in the profession,” particularly because Leisz was the Sanders County Attorney at the time. It identified:

• Aggravating factors:
  • Refusal to cooperate with law enforcement;
  • The false insurance claim itself;
  • Her misstatement to ODC that she was going on inactive status (when she did not complete that process).
• Mitigating factors:
  • Sincere remorse;
  • Many years of practice without disciplinary incidents since 2006;
  • Voluntary withdrawal from practice for a substantial period;
  • No monetary harm to any client.

C. The Supreme Court’s Decision

The Montana Supreme Court:

• Reviewed the Commission’s findings, conclusions, and recommendation de novo, citing In re Neuhardt, 2014 MT 88, ¶ 16, 374 Mont. 379, 321 P.3d 833.
• Expressly considered the disciplinary criteria in MRLDE 9(B).
• Accepted the Commission’s recommendation in full.

The Court ordered:

1. Acceptance of Rule 26 Conditional Admission: The Court accepted and adopted the Commission’s recommendation to approve Leisz’s conditional admission under MRLDE 26.
2. 60‑Day Suspension:
   • Leisz is suspended from the practice of law in Montana for 60 days.
   • The suspension is effective 30 days from the date of the Order (i.e., a built-in transition period formally mandated by the Court).
3. Notice Requirements: Under MRLDE 29 and 30, Leisz must notify:
   • All clients in pending matters;
   • All co-counsel in pending matters;
   • All opposing counsel and self-represented adverse parties in pending matters;
   • All courts where she appears as counsel of record.
4. Costs: She must pay the costs of the proceedings, subject to MRLDE 9(C)(4)(a).
5. Filing and Service: Pursuant to MRLDE 26(D), the Clerk must file the conditional admission and Commission materials with the Order and serve or distribute it to:
   • Leisz;
   • Disciplinary Counsel;
   • The Commission on Practice;
   • All Montana District Court clerks and judges;
   • The U.S. District Court for the District of Montana;
   • The Ninth Circuit Court of Appeals;
   • The Executive Director of the State Bar of Montana.

The result is a public, formal, time-limited suspension for an elected prosecutor whose personal conduct involved criminal dishonesty and misleading statements to disciplinary authorities.

III. Analysis

A. Precedents and Authorities Cited

1. In re Neuhardt (2014 MT 88) – Standard of Review

The Court cites In re Neuhardt, 2014 MT 88, ¶ 16, 374 Mont. 379, 321 P.3d 833, for the proposition that:

This Court reviews de novo the Commission’s findings of fact, conclusions of law, and recommendations.

In Montana attorney discipline:

• The Commission on Practice conducts hearings, develops a record, and makes findings and recommendations.
• The Supreme Court is not bound by those conclusions; it independently (de novo) reviews the:
  • Facts as found by the Commission;
  • Legal conclusions drawn from those facts; and
  • Recommended sanction.

By reaffirming Neuhardt, the Leisz Order underscores that the Montana Supreme Court is the final, independent arbiter of attorney discipline, even where the parties have negotiated a conditional admission and the Commission recommends its acceptance. The Court nevertheless chose to align itself with the Commission in this case.

2. Montana Rules of Professional Conduct – Rule 8.4

The opinion identifies a single professional rule violation: M. R. Pro. Cond. 8.4, the general “professional misconduct” rule.

While the order does not reproduce the text, Rule 8.4 typically provides that it is professional misconduct for a lawyer to, among other things:

• Commit a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness or fitness as a lawyer;
• Engage in conduct involving dishonesty, fraud, deceit, or misrepresentation;
• Engage in conduct that is prejudicial to the administration of justice.

Leisz’s admitted misconduct—lying to her insurer about who was driving, being charged with felony insurance fraud, ultimately pleading guilty to obstructing justice, and misrepresenting her licensing status to ODC—squarely implicates the dishonesty and criminal conduct components of Rule 8.4.

A crucial doctrinal point reinforced here: Rule 8.4 applies to a lawyer’s personal life, not just to conduct in representation of clients. The Court’s acceptance of discipline based solely on “personal” misconduct confirms that:

• Dishonest conduct in private affairs can be professional misconduct.
• A reduced criminal charge (from felony to misdemeanor) does not insulate a lawyer from serious disciplinary consequences.

3. MRLDE 9(B) – Disciplinary Criteria

The Court states that, in deciding the appropriate sanction, it considered “the disciplinary criteria enumerated in MRLDE 9(B).”

Although the text of 9(B) is not set out in the order, provisions like MRLDE 9(B) typically codify factors similar to the ABA Standards for Imposing Lawyer Sanctions, such as:

• The duty violated (to client, public, legal system, or profession);
• The lawyer’s mental state (intentional, knowing, negligent);
• The actual or potential injury to clients, the public, or the judicial system;
• Aggravating and mitigating circumstances.

By invoking MRLDE 9(B), the Court signals that the sanction is not simply negotiated or ad hoc; rather, it is grounded in a structured, factor-based analysis of:

• Seriousness of the dishonest conduct;
• The fact that she was the elected county attorney;
• The interplay of aggravators and mitigators.

4. MRLDE 26 – Conditional Admission and Affidavit of Consent

Leisz’s discipline is based on a conditional admission under MRLDE 26(B)(3). Under this rule:

• The respondent attorney admits the factual allegations and rule violations;
• The attorney and ODC agree to a specific form of discipline;
• The agreement is conditional upon acceptance by the Commission and, ultimately, by the Supreme Court.

MRLDE 26(D) requires that, when such an admission is accepted, the Clerk file the conditional admission and the Commission’s findings and recommendations with the Court’s order. That is why the order specifically directs the Clerk to do so—ensuring the record of the misconduct and its resolution is complete and public.

The procedural history is also instructive:

• Leisz’s first conditional admission (with lesser discipline) was rejected by the Commission.
• Only after the sanction was increased to a 60‑day suspension did the Commission recommend and the Court approve the conditional admission.

This reinforces two points:

1. Conditional admissions are not purely private deals between ODC and the lawyer; they are subject to independent scrutiny by both the Commission and the Court.
2. The disciplinary system will require sanctions that align with public protection and confidence, even if the parties initially propose something more lenient.

5. MRLDE 29 and 30 – Notice and Winding Up of Practice

The Court repeatedly references MRLDE 29 and 30, which together govern:

• The duties of a suspended or disbarred lawyer; and
• The required notices to clients, courts, and others when the lawyer may no longer practice.

Among other things, these rules typically require:

• Prompt written notice to all current clients in pending matters;
• Notification to co-counsel and opposing counsel or parties;
• Steps to protect clients’ interests—returning files, refunding unearned fees, and advising clients to seek other counsel;
• Notification to courts where the lawyer appears as counsel of record.

Notably, Leisz previously told ODC she was going to inactive status but did not complete the formal process. That misstatement became an aggravating factor. In contrast, the Court’s order ensures that this time, the transition out of practice—albeit temporary—is governed by clear, enforceable formal notice obligations.

6. MRLDE 9(C)(4)(a) – Costs

The order states that Leisz must pay the costs of the proceedings, “subject to the provisions of MRLDE 9(C)(4)(a).” While the specific language is not quoted, rules like this typically:

• Authorize assessment of costs (investigation, hearing transcripts, etc.) against the lawyer;
• May allow for payment plans, partial waivers, or other discretion in appropriate cases.

Cost-shifting emphasizes that disciplinary proceedings are not funded by the public or by other lawyers when the lawyer’s own misconduct prompted the process.

B. The Court’s Legal Reasoning

1. Nature of the Misconduct under Rule 8.4

The misconduct has three closely related components:

1. False insurance claim: Deliberately claiming to be the driver in an accident when she was not.
2. Criminal resolution: Being charged with felony insurance fraud and ultimately pleading guilty to obstructing justice.
3. Misrepresentation to ODC: Telling ODC she was going on inactive status, without actually effectuating that status with the State Bar.

Each component engages Rule 8.4:

• The false insurance claim and the obstruction plea are conduct involving dishonesty and misrepresentation, and they constitute criminal behavior reflecting adversely on her honesty and fitness.
• The misstatement to ODC undermines the integrity of the disciplinary system itself and reflects a willingness to mislead a regulatory body charged with overseeing attorney conduct.

A key doctrinal message: the fact that the insurer has not sought reimbursement—or that coverage may ultimately have existed—is irrelevant to the disciplinary analysis. The focus is on:

• The lawyer’s mental state (intentional dishonesty); and
• The potential injury to the integrity of legal and financial systems (insurance and the administration of justice).

2. Role as County Attorney – Heightened Public-Trust Concerns

The Commission, and implicitly the Court, place particular weight on the fact that Leisz was the Sanders County Attorney when the core misconduct occurred.

A county attorney is an elected prosecutor who:

• Exercise[s] prosecutorial power on behalf of the state;
• Works closely with law enforcement;
• Is a public official whose role depends on public trust.

The Commission concluded that anything less than a 60‑day suspension would “erode public confidence in the profession,” especially given her prosecutorial position. The Supreme Court, by accepting this conclusion, effectively affirms that:

• Prosecutors are held to a particularly high standard of integrity, even in their personal affairs.
• Criminal conduct involving dishonesty by a prosecutor is not merely private misbehavior; it reflects on the government’s administration of justice and public confidence.

This does not mean that every prosecutor’s misdemeanor will automatically trigger suspension, but it does confirm that:

When the misconduct directly implicates honesty and the lawyer’s relationship to law enforcement and the criminal justice system, suspension (as opposed to reprimand) is a presumptively appropriate response.

3. Aggravating and Mitigating Factors – MRLDE 9(B) in Action

Although the Court does not reproduce a factor-by-factor analysis, the Commission’s discussion, adopted by the Court, reveals their reasoning.

a. Aggravating Factors

• Refusal to cooperate with law enforcement: This undermines the criminal justice system—precisely the system a county attorney is sworn to uphold.
• False insurance claim: An intentional misrepresentation made for financial benefit is at the core of dishonest conduct condemned by Rule 8.4.
• Misstatement to ODC regarding inactive status: Misleading the regulatory body about compliance with bar-status requirements compounds the original misconduct and reflects disregard for regulatory processes.
• Prior discipline (2006): While not highlighted as a separate bullet, the fact of prior discipline is inherently aggravating; it shows that earlier corrective efforts did not prevent later misconduct.

b. Mitigating Factors

• Sincere remorse: The Commission expressly found her remorse genuine.
• Long practice with no recent incidents: Many years of practice since 2006 without further disciplinary issues weighed in her favor.
• Voluntary withdrawal from practice: She ceased practicing for approximately 14 months during the pendency of her criminal case, which the Commission credited as mitigation even though she did not formally go inactive.
• No client monetary harm: While public and systemic harm existed, no client suffered direct financial injury from her conduct.

Balancing these factors, the Commission and Court implicitly concluded that:

• Public protection and deterrence demanded a real suspension; but
• Her remorse, self-reporting, and voluntary cessation of practice justified a relatively short suspension (60 days, instead of a lengthier one).

4. Why 60 Days and Not 30 – Protecting Public Confidence

The order reveals that ODC and Leisz originally agreed to a 30‑day suspension, but the Commission indicated that was too lenient. Only after the sanction was increased to 60 days did the Commission recommend acceptance.

The Commission articulated the crux of the issue:

Lesser discipline would erode public confidence in the profession, particularly in light of the fact that Leisz was the Sanders County Attorney at the time of the incident.

By adopting this recommendation, the Court implicitly endorses 60 days as the minimum adequate response for:

• A prosecutor’s intentional dishonesty in a financial transaction (insurance claim);
• Resulting criminal conviction (even as a misdemeanor);
• Related misrepresentations to the disciplinary authority.

At the same time, the Court stopped short of harsher sanctions (e.g., longer suspension or disbarment), reflecting:

• Recognition of meaningful mitigation (self-reporting, remorse, voluntary non-practice); and
• The plea to a misdemeanor rather than a felony, with no evidence of client harm or misappropriation of client funds.

5. The Limited Weight of “Voluntary” Non‑Practice

One important doctrinal nuance is the Court’s treatment of Leisz’s 14‑month voluntary cessation of practice. Her counsel argued that she stopped practicing after informing ODC she expected discipline.

The Commission and Court:

• Treated this as a mitigating factor (voluntary withdrawal from practice); but
• Did not treat it as a substitute for formal discipline, nor did they credit it as time already “served” toward suspension.

The reasoning is clear:

• Discipline serves not only to limit the lawyer’s ability to practice but also to:
  • Publicly acknowledge wrongdoing;
  • Reinforce norms of honesty and integrity;
  • Maintain systemic confidence.
• Informal or self-imposed restrictions—especially when unaccompanied by formal status changes or public notice—do not accomplish those systemic purposes.

This sends a message to lawyers facing potential discipline: self-imposed inactivity may mitigate sanction, but it will not replace it, and failure to formalize status changes can itself be treated as misconduct.

C. Impact and Future Implications

1. For Prosecutors and Public Officials

The most immediate impact of the Leisz decision is on prosecutors and other public lawyers in Montana:

• It reinforces that personal dishonesty involving criminal conduct is incompatible with prosecutorial office, even if unrelated to a specific case.
• Criminal charges reduced to a misdemeanor will not automatically soften professional consequences when the underlying conduct was serious and intentional.
• Courts will consider whether a lenient sanction might “erode public confidence”—a particularly salient concern when the lawyer holds a public trust position.

Future cases involving prosecutors will likely cite this matter as support for suspension-level sanctions when:

• The misconduct involves deliberate misrepresentation or obstruction; or
• There is non-cooperation or deception toward law enforcement or regulatory bodies.

2. For All Lawyers – Personal vs. Professional Conduct

The case underscores a key theme in modern professional-responsibility jurisprudence: the divide between “personal” life and “professional” life is not absolute.

Leisz’s actions did not involve:

• A client;
• A court filing in a case she was handling as counsel;
• Misuse of client funds.

Yet they:

• Involved intentional dishonesty for personal financial benefit;
• Led to a criminal conviction for obstructing justice;
• Included misstatements to the disciplinary authority.

The Court’s acceptance of suspension under Rule 8.4 confirms that:

• Lawyers are expected to adhere to standards of honesty at all times, not only in their representation of clients.
• Insurance fraud, tax fraud, obstruction, and similar offenses—committed personally—can lead to significant professional discipline.

3. Conditional Admissions and the Role of the Commission on Practice

The opinion demonstrates the practical operation of conditional admissions under MRLDE 26:

• They expedite resolution by avoiding full contested hearings on liability.
• They still require Commission and Court approval of both the admission and the sanction.
• The Commission may reject an initial agreement it deems too lenient, prompting renegotiation of sanctions.

In this sense, the Commission operates functionally as a safeguard against “under‑disciplining,” ensuring the negotiated resolution aligns with the broader public-protection purpose of the disciplinary system.

4. Notice and Transparency

The Court’s detailed instructions to the Clerk—to file and distribute the Order and the underlying admission and Commission documents to every Montana District Court, the federal district court, the Ninth Circuit, and the State Bar—aren’t mere formalities. They underscore:

• The disciplinary process is public and transparent, particularly for a public official like a county attorney.
• Other courts and tribunals must be able to rely on accurate, up‑to‑date information about a lawyer’s disciplinary status.

This enhances:

• Reciprocal discipline (other jurisdictions may take action based on Montana’s order);
• Judicial and litigant confidence that suspended lawyers are not appearing improperly.

IV. Simplifying Key Legal and Procedural Concepts

This section explains several technical terms and mechanisms used in the opinion, in more accessible language.

1. Office of Disciplinary Counsel (ODC)

ODC is the entity responsible for:

• Investigating complaints of lawyer misconduct in Montana;
• Prosecuting disciplinary cases before the Commission on Practice;
• Negotiating conditional admissions or settlement agreements in appropriate cases.

2. Commission on Practice

The Commission is a body (often comprising lawyers and sometimes non-lawyers) that:

• Holds hearings on disciplinary complaints;
• Makes formal findings of fact and conclusions of law;
• Recommends a sanction (or no sanction) to the Montana Supreme Court.

The Commission does not impose final discipline; its recommendations are reviewed de novo by the Supreme Court.

3. “De Novo” Review

“De novo” review means:

• The reviewing court looks at the matter afresh, without deferring to prior decisions;
• The Supreme Court is free to accept, modify, or reject the Commission’s findings and recommendations.

In practice, the Commission’s work is highly influential, but not binding.

4. Conditional Admission and Affidavit of Consent (MRLDE 26)

A conditional admission is essentially a plea agreement in the disciplinary context:

• The lawyer admits the truth of the factual allegations and the rule violation(s);
• The lawyer and ODC agree on a specific sanction (e.g., suspension, reprimand);
• The agreement is “conditional” because it only takes effect if the Commission and the Supreme Court approve it.

If the Court accepts the conditional admission, it issues an order imposing the agreed sanction, as here.

5. Suspension vs. Inactive Status

• Suspension:
  • A formal disciplinary penalty imposed by the Court.
  • Time-limited (e.g., 60 days) but carries public stigma and formal obligations (notice, winding up, often conditions on reinstatement).
• Inactive status:
  • An administrative licensing status with the State Bar, often requested voluntarily (e.g., for retirement, relocation, or temporary non-practice).
  • Not inherently disciplinary, though a lawyer on inactive status may not practice law.

In Leisz’s case, her statement to ODC that she was “going inactive” without actually changing her status formally was treated as an aggravating factor, because it was misleading. Formal status changes must be made through proper channels.

6. Aggravating and Mitigating Factors

In disciplinary cases:

• Aggravating factors are circumstances that justify a more severe sanction, such as:
  • Prior discipline;
  • Dishonest or selfish motive;
  • Refusal to cooperate with the disciplinary process;
  • Substantial experience in practice (when misused).
• Mitigating factors are circumstances that can justify a less severe sanction, such as:
  • Absence of prior discipline (or long gap since prior discipline);
  • Personal or emotional difficulties where relevant;
  • Remorse and acceptance of responsibility;
  • Cooperation with ODC;
  • Imposition of other penalties (e.g., criminal sentence).

In this case, both categories were carefully weighed to arrive at a 60‑day suspension.

7. Notice Requirements (MRLDE 29 and 30)

When a lawyer is suspended, she cannot simply disappear from existing cases. Rules 29 and 30 require that she:

• Promptly inform clients and courts of her inability to continue representation;
• Help clients transition to new counsel or otherwise protect their interests;
• Formally confirm to the Court and Bar that these steps have been taken.

This is designed to ensure that discipline imposed on the lawyer does not harm existing clients or disrupt court proceedings.

V. Conclusion – Significance of the Leisz Decision

The Leisz disciplinary order is not a sweeping doctrinal overhaul, but it meaningfully refines and reinforces several important principles in Montana lawyer discipline:

1. Dishonesty in personal affairs can be professional misconduct. A false insurance claim and subsequent obstruction of justice—even outside client representation—squarely violate Rule 8.4 and justify suspension.
2. Prosecutors bear heightened responsibility. As Sanders County Attorney, Leisz’s misconduct was particularly damaging to public trust. The Commission and Court emphasized that anything less than a 60‑day suspension would erode confidence in the profession, especially in the prosecutorial context.
3. Self-reporting and voluntary self-restrictions mitigate but do not replace discipline. Leisz’s self-report to ODC and her 14‑month voluntary cessation of practice were credited in mitigation, but the Court still imposed a formal, public suspension.
4. Honesty toward disciplinary authorities is non-negotiable. Misstating one’s status (e.g., claiming to be going inactive without completing the process) is itself an aggravating factor and demonstrates disrespect for regulatory oversight.
5. Conditional admissions are subject to independent scrutiny. The Commission rejected an initial 30‑day suspension as too lenient and only recommended acceptance of the conditional admission once the sanction was increased to 60 days. The Supreme Court’s adoption of that recommendation reaffirms that negotiated resolutions are vetted against the overriding goal of public protection.

In the broader legal context, In re Naomi R. Leisz stands as a clear warning to Montana lawyers—particularly those in public office—that:

• Personal financial dishonesty and obstruction of justice are incompatible with the privilege of practicing law;
• Prosecutors must maintain personal integrity commensurate with their role in enforcing the law; and
• The disciplinary system will impose public, formal sanctions to maintain public confidence, even where the lawyer has already faced criminal punishment and has taken some voluntary remedial steps.

As such, the decision is likely to be cited in future cases involving prosecutors’ personal misconduct, conditional admissions under MRLDE 26, and the appropriate balance between mitigation and the need to protect public trust in the legal profession.