Reaffirming Mandatory CLE and Administrative Suspension under Pa.R.C.L.E. 111(b)

I. Introduction

On November 19, 2025, the Supreme Court of Pennsylvania issued an order titled “Attorneys Administratively Suspended Pursuant to Rule Pa.R.C.L.E. 111(b)”. Attached to that order is a multi-page report generated by the Pennsylvania Continuing Legal Education (CLE) Board, dated November 18, 2025, identifying lawyers who are non-compliant with their CLE obligations for the compliance year ending April 30, 2025 (“Group 1”).

The document is not a traditional, reasoned appellate opinion. Instead, it is an administrative enforcement order backed by a detailed list of attorneys—classified as Active, Emeritus, and Limited In-House Corporate Counsel—who have failed, as of the reporting date, to satisfy CLE requirements and for whom a reinstatement fee has been assessed.

The lead notice states:

“The attorneys on the attached list have the opportunity to comply with outstanding requirements prior to the effective date of the Supreme Court Order and not be administratively suspended.”

This language frames the order as a conditional step toward administrative suspension under Pa.R.C.L.E. 111(b): unless the identified attorneys cure their CLE deficiencies before the order’s effective date, their licenses will move from active (or equivalent) status to administrative suspension.

This commentary analyzes the order and its attachment within the structure of Pennsylvania’s regulation of the bar, explaining the legal framework, implicit reasoning, and practical impact of enforcing CLE noncompliance through administrative suspension.

II. Background and Procedural Context

A. Mandatory Continuing Legal Education in Pennsylvania

Pennsylvania, like nearly all U.S. jurisdictions, requires licensed attorneys to complete a minimum number of CLE credits within a defined reporting period. The specifics (number of credits, ethics requirements, etc.) are set out in the Pennsylvania Rules for Continuing Legal Education (Pa.R.C.L.E.).

Attorneys are generally assigned to compliance “groups,” with each group having its own annual deadline. The report at issue concerns:

Group 1 attorneys, with a year-end date of April 30, 2025.

The CLE Board monitors compliance, sends reminders and deficiency notices, and, for persistent noncompliance, ultimately certifies those attorneys to the Supreme Court for administrative suspension under Rule 111.

B. Rule Pa.R.C.L.E. 111(b): Noncompliance and Referral to the Court

Although the full text of Rule 111(b) is not reproduced in the document, the report explicitly states that the contemplated suspensions are “pursuant to Rule Pa.R.C.L.E. 111(b)”. In substance, Rule 111(b):

Authorizes the CLE Board to identify attorneys who remain in noncompliance after appropriate notice and opportunity to cure; and
Provides a mechanism by which the Board, after those efforts, certifies the names of such attorneys to the Supreme Court; and
Empowers the Supreme Court to enter an administrative suspension order for those attorneys.

The order here is an instance of that mechanism in operation: the CLE Board generates the non-compliance list (with detailed sorting and counts), and the Supreme Court uses that list as the basis for an impending suspension order.

C. Nature of Administrative Suspension

An administrative suspension is not, in itself, a disciplinary finding of misconduct in the same sense as disbarment or public censure. Rather, it is a regulatory status change triggered by objective noncompliance (for example, failure to complete CLE or to pay annual fees).

However, the consequences of practicing law while administratively suspended are serious:

Doing so can constitute the unauthorized practice of law.
That unauthorized practice can then support formal disciplinary charges under the Pennsylvania Rules of Disciplinary Enforcement.
It may also have malpractice or contractual implications with clients and employers.

Thus, even though an administrative suspension is “non-disciplinary” in form, it is tightly interwoven with the disciplinary structure.

III. Summary of the Order and Attached CLE Report

A. Core Content of the Document

The document provided consists of:

A notice paragraph indicating that attorneys on the attached list may avoid administrative suspension by coming into CLE compliance before the effective date of the Supreme Court’s order.
A multi-page report generated by Pennsylvania Continuing Legal Education staff (user ID “jilgenfr”), labeled “NON-COMPLIANT LAWYERS,” with data fields including:
- Status (Active, Emeritus, Limited In-House Corporate Counsel)
- County code (or “Out Of State”)
- Attorney ID number
- Attorney’s name
A specification of the criteria used for the list:
- GROUP 1 YEAR END DATE = 04302025, and
- REINST FEE ASSESSED
Totals by county and status, including:
- 407 attorneys in Active status;
- 1 attorney in Emeritus status; and
- 2 attorneys in Limited In-House Corporate Counsel status;
- Total reported: 410 lawyers.

The report organizes attorneys alphabetically within counties (e.g., Philadelphia, Lancaster, Northampton, Allegheny, etc.), culminating in a substantial “Out Of State” category—indicating that PA-admitted lawyers residing or primarily practicing elsewhere remain subject to Pennsylvania CLE enforcement.

B. What the Order Actually Does

From the content provided, the order and its attachment do the following:

Identify attorneys in Group 1 whose CLE records show noncompliance as of the report date and for whom a reinstatement fee has already been assessed.
Provide advance notice that these attorneys are scheduled for administrative suspension under Pa.R.C.L.E. 111(b), but that they may avoid that outcome by:
- Completing their outstanding CLE requirements, and
- Addressing any related fees,
before the order’s effective date.
Signal to courts, clients, and the bar at large that as of the effective date (once it arrives), those on the list who have not cured their noncompliance will no longer be authorized to practice law in Pennsylvania.

Importantly, the language of the notice makes clear that, at the time of the report, the suspensions are prospective and conditional. The order is part of a process that includes an opportunity to cure, not an immediate, retroactive deprivation of license.

IV. Legal Framework and Underlying Authority

A. Pa.R.C.L.E. 111(b): Structural Role

Rule 111(b) (Noncompliance) sits within the broader scheme of the CLE rules. While the exact text is not reproduced, the structure implied by this order is as follows:

Initial CLE obligations are set elsewhere in the CLE rules (credits, ethics, etc.).
Monitoring and notice: The CLE Board tracks attorney compliance and issues notices when deficiencies appear (often including grace periods and opportunities to cure without suspension).
Escalation: When an attorney remains noncompliant after prior notice, the CLE Board identifies that attorney as subject to potential suspension and assesses a reinstatement fee (indicated in the report’s criteria line).
Certification to the Court: Under 111(b), the Board certifies a list of such attorneys to the Supreme Court.
Administrative suspension order: The Supreme Court, acting under its inherent and rule-based authority to regulate the bar, issues an order administratively suspending those attorneys as of a stated effective date—unless they have, in the interim, demonstrated compliance.
Reinstatement: Attorneys later seeking to resume practice must complete CLE requirements, pay fees, and follow whatever reinstatement process the rules require.

The order at issue reflects steps 4 and 5 in this chain.

B. Relation to the Rules of Disciplinary Enforcement

Although this document cites only Pa.R.C.L.E. 111(b), its practical consequences are governed in part by the Pennsylvania Rules of Disciplinary Enforcement (Pa.R.D.E.), which:

Define what it means to be in “good standing” to practice law;
Set out consequences for practicing while suspended;
Specify notice and communication obligations when status changes (e.g., notifying courts, clients, co-counsel, and opposing counsel of an attorney’s suspension).

Thus, a CLE-based administrative suspension is both:

a CLE rule issue (failure to meet educational requirements), and
a disciplinary enforcement issue once the attorney’s status changes and they must refrain from practice unless properly reinstated.

C. Judicial Authority Over the Practice of Law

The Supreme Court of Pennsylvania holds inherent constitutional authority to regulate the practice of law and the admission and discipline of attorneys in the Commonwealth. Through rules such as Pa.R.C.L.E. and Pa.R.D.E., it delegates day-to-day administration to entities like the CLE Board while retaining ultimate decision-making power to suspend or reinstate.

The order is therefore not merely bureaucratic; it is the Court’s exercise of that constitutional and rule-based supervisory power, implemented through a routine but consequential mechanism—administrative suspension for CLE noncompliance.

V. “Precedents” and Prior Practice

A. Absence of Cited Case Law

The document itself contains no citations to case law or prior Supreme Court opinions. This is typical of administrative suspension orders. They generally function as implementing instruments rather than as vehicles for doctrinal development.

Accordingly, this order does not, on its face, announce a new legal principle or overrule any prior case. It is an application of existing rules (especially Pa.R.C.L.E. 111(b)).

B. Continuity with Prior CLE Suspension Orders

Pennsylvania’s Supreme Court has long used similar list-based orders to suspend attorneys for:

Non-payment of annual fees (under disciplinary rules), and
Noncompliance with CLE requirements (under Pa.R.C.L.E. 111).

Those orders share common features:

An attachment listing attorneys by name and number;
Identification of the regulatory basis for the suspension (e.g., a specific rule);
Prospective effective dates with opportunities to cure.

The present order is consistent with that established pattern. In that sense, its significance lies not in creating new law but in reaffirming and continuing an established regulatory practice.

C. Comparative Context (Other Jurisdictions)

Many jurisdictions follow similar approaches:

Mandatory CLE is universal or nearly so in the United States.
Failure to comply typically results in administrative suspension or inactive status.
Supreme courts or bar authorities often publish lists of noncompliant attorneys.

Viewed against this national backdrop, Pennsylvania’s use of Pa.R.C.L.E. 111(b) is mainstream regulatory practice, not an outlier. The order underscores Pennsylvania’s commitment to enforcing CLE rigorously.

VI. Implicit Legal Reasoning and Embedded Principles

Although the order contains no extended reasoning, it rests on several implicit legal and policy premises derived from the CLE rules and the Court’s supervisory authority.

A. CLE as a Condition of the Ongoing License to Practice

By conditioning the right to practice on compliance with CLE, the Court affirms that:

The law is continually evolving; initial legal education is insufficient for a decades-long career.
Ongoing competence is a regulatory requirement, not a mere professional aspiration.
Failure to meet this requirement places attorneys in a status where they may no longer safely and lawfully represent clients.

The very existence of Pa.R.C.L.E. 111(b)—and orders like this—reinforces that the license to practice law is conditional and continuing, rather than a one-time entitlement.

B. Due Process: Notice and Opportunity to Cure

The notice at the top of the document is particularly important:

“The attorneys on the attached list have the opportunity to comply with outstanding requirements prior to the effective date of the Supreme Court Order and not be administratively suspended.”

This embodies key due-process protections:

Notice: Attorneys are informed that their status is in jeopardy and that the Court intends to suspend them for CLE noncompliance.
Opportunity to cure: They are given a chance, prior to the effective date, to complete CLE credits and satisfy fees to avoid suspension.
Predictability: The criteria are clear—Group 1, year-end April 30, 2025; noncompliance; reinstatement fee assessed.

While the order does not spell out all procedural steps, the combination of:

Rule-based notice processes (under Pa.R.C.L.E.), and
Advance publication of the list prior to suspension

provides a structured framework that balances regulatory enforcement with fairness to attorneys.

C. Uniform Application Across Attorney Categories

The report separately identifies:

Active attorneys (the overwhelming majority);
Emeritus attorneys (1 lawyer); and
Limited In-House Corporate Counsel attorneys (2 lawyers).

This confirms that:

All licensure categories subject to CLE rules are equally subject to enforcement via administrative suspension.
Retirement-leaning or limited-practice statuses (e.g., emeritus, in-house only) still carry CLE obligations unless the rules expressly exempt them.
Out-of-state residence or primary practice does not exempt a PA-admitted lawyer from Pennsylvania CLE obligations.

That uniformity advances the principle that the Court’s regulatory interests—competence and public protection—apply to every lawyer holding the privilege of Pennsylvania admission.

D. Transparency and Public Protection

The detailed, county-by-county listing serves a transparency function:

Courts, clients, employers, and co-counsel can verify whether a given attorney appears on the noncompliance list.
Public disclosure of noncompliance creates regulatory pressure to cure deficiencies and reinforces professional norms of timely compliance.

In effect, the list functions as both:

a regulatory instrument (operatively tied to suspension), and
a public notice that advances the Court’s duty to protect consumers of legal services.

VII. Impact and Practical Consequences

A. For the Listed Attorneys

For the approximately 410 lawyers identified, the order has direct and immediate implications:

Urgent obligation to cure: They must complete outstanding CLE credits and satisfy any associated fees before the order’s effective date to avoid being placed on administrative suspension.
Risk to current representations: If they fail to cure and become suspended, they may no longer appear in court, sign pleadings, or provide legal services in Pennsylvania. Ongoing matters may need to be transferred or co-counsel substituted.
Reinstatement hurdles: Once suspended, they will need to comply fully with CLE, pay reinstatement fees, and complete any administrative reinstatement procedures. Practice cannot resume until formal reinstatement is granted.

Attorneys listed under special statuses (emeritus, in-house counsel) face similar consequences, adapted to the scope of their authorized practice. For example, an in-house counsel’s ability to act as legal counsel within a corporation in Pennsylvania would be impaired by suspension.

B. For Courts, Clients, and the Public

For courts and the public, the order enhances:

Reliability of representation: Courts can better ensure that attorneys appearing before them are in good standing and CLE-compliant.
Client protection: Clients have an additional tool (and signal) to verify the standing of their lawyer, especially around the effective date of the suspension order.
Administrative clarity: Court clerks, disciplinary agencies, and insurers have a clear, official record of those who are noncompliant as of the report date.

The publication of such lists is a prophylactic measure; it helps prevent clients from unwittingly being represented by attorneys whose licenses are about to be restricted.

C. For the Regulatory System and Future Cases

In the broader regulatory ecosystem, this order:

Reinforces the seriousness of CLE compliance: It signals that failure to meet CLE requirements is not a benign paperwork issue but a status-defining deficiency.
Establishes a factual predicate for any future proceedings concerning unauthorized practice (e.g., if an attorney were to practice after suspension, this order would constitute part of the record establishing notice and status).
Encourages systemic compliance by demonstrating that noncompliance leads to visible and enforceable consequences, not just quiet reminders.

While the order does not set a new doctrinal precedent, it will likely be cited in future disciplinary files as evidence of status and notice for particular attorneys in any subsequent enforcement proceedings.

VIII. Simplifying Key Legal and Regulatory Concepts

Several technical concepts appear or are implied in the document. The following explanations are intended to make them clear to non-specialists.

Pa.R.C.L.E.: Abbreviation for the Pennsylvania Rules for Continuing Legal Education. These rules govern how many CLE credits lawyers must complete, what kinds of courses count, and what happens when they do not comply.
Rule 111(b): The specific CLE rule addressing what happens when an attorney fails to comply with CLE requirements. Subsection (b) provides the mechanism by which the CLE Board certifies noncompliant attorneys to the Supreme Court, which may then issue administrative suspension orders.
Administrative Suspension: A regulatory status in which an attorney is prohibited from practicing law because of noncompliance with administrative or regulatory obligations (such as CLE or fee payments). It is distinct from disbarment or suspension imposed as a sanction for misconduct but has the same practical effect—no lawful practice—until reinstatement.
Continuing Legal Education (CLE): Ongoing education that lawyers must complete after admission to stay current on legal developments, ethics, and practice skills. Measured in credit hours per reporting period.
Compliance Groups: Administrative groupings (such as “Group 1”) that determine an attorney’s annual CLE deadline. In this order, Group 1’s reporting year ends on April 30, 2025.
Reinstatement Fee Assessed: An additional fee charged to attorneys who have already failed to meet CLE deadlines. Its assessment, as noted in the report criteria, signals that the noncompliance has progressed to the stage where administrative suspension is being sought.
Active Status: The normal status of a practicing attorney who is authorized to perform all activities constituting the practice of law (subject to any limited scope authorizations).
Emeritus Status: A special status often used by attorneys who are largely retired but may still perform limited or pro bono legal work under defined conditions. In Pennsylvania, emeritus attorneys may remain subject to CLE obligations unless specifically exempted.
Limited In-House Corporate Counsel: A status allowing lawyers who are not otherwise admitted in Pennsylvania to practice law solely as in-house counsel for an employer (such as a corporation) in the Commonwealth, under a limited license. These attorneys, as shown by the report, are also subject to CLE compliance.
Out-of-State Category: In the report, “Out Of State” refers to attorneys who are admitted in Pennsylvania but whose recorded address is outside the Commonwealth. They remain subject to Pennsylvania CLE requirements unless otherwise exempted.

IX. Conclusion

The Supreme Court of Pennsylvania’s order titled “Attorneys Administratively Suspended Pursuant to Rule Pa.R.C.L.E. 111(b)” is a paradigmatic example of the Court’s routine yet powerful use of administrative suspension to enforce mandatory continuing legal education.

Although the document does not contain doctrinal analysis or case citations, it:

Implements Pa.R.C.L.E. 111(b) by moving noncompliant Group 1 attorneys toward administrative suspension;
Provides clear notice and an opportunity to cure before the suspensions take effect;
Applies uniformly across standard active status, emeritus attorneys, and limited in-house corporate counsel;
Publicly identifies approximately 410 lawyers as of November 18, 2025, as noncompliant for the CLE year ending April 30, 2025, with reinstatement fees assessed;
Strengthens the regulatory linkage between CLE compliance and an attorney’s continued authorization to practice.

While the order does not itself create new substantive law, it reaffirms and operationalizes a key regulatory principle: ongoing competence, demonstrated in part through compliance with continuing legal education requirements, is a condition of the privilege to practice law in Pennsylvania. Attorneys who neglect that obligation risk not only their professional standing but also, if they practice while suspended, subsequent disciplinary sanctions.

In the broader legal context, this order underscores the Court’s sustained commitment to public protection, professional accountability, and the integrity of the legal system, all enforced through the seemingly technical—but ultimately substantive—mechanism of CLE-based administrative suspension under Pa.R.C.L.E. 111(b).