Unauthorized Use of Judicial Signature Stamps and Court Seals for Personal Benefit Constitutes CJC 1.3 “Abuse” Warranting Removal

1. Introduction

In re Disciplinary Proc. Against Ruzumna is a Washington Supreme Court judicial-discipline decision reviewing a Commission on Judicial Conduct (Commission) order that censured and recommended removal of David Ruzumna, a judge pro tempore. The case arose from an undisputed episode in which Judge Pro Tem Ruzumna used (without permission) (1) the King County District Court seal and (2) the signature stamp of the elected judge for whom he was sitting pro tem, to create a document stating he was employed by the court and to present it to a parking attendant in an effort to obtain a county-employee parking discount.

The central issues were (a) whether this conduct violated Canon 1 of the Code of Judicial Conduct (CJC) Rules 1.1, 1.2, and 1.3, and (b) whether the appropriate sanction was merely an admonishment (as Ruzumna urged) or the more severe combination of censure and removal (as the Commission recommended).

2. Summary of the Opinion

The Supreme Court, applying de novo review to the Commission record, held that clear, cogent, and convincing evidence supported findings that Judge Pro Tem Ruzumna violated CJC 1.1 (compliance with law), CJC 1.2 (promoting confidence in the judiciary and avoiding impropriety/appearance), and CJC 1.3 (avoiding abuse of the prestige of judicial office). The court rejected the argument that the episode merited only admonishment and concluded that censure and removal was the appropriate sanction.

Two themes drove the result: (1) the misappropriation of official judicial insignia (another judge’s signature stamp and the court seal) to obtain a personal economic benefit is, by its nature, a serious integrity violation; and (2) the Commission-supported finding that Ruzumna engaged in ongoing dishonesty during the disciplinary process aggravated the misconduct and undermined fitness for judicial service.

3. Analysis

3.1. Precedents Cited

  • In re Disciplinary Proc. Against Buchanan, 100 Wn.2d 396 (1983)
    Role in the opinion: Used to describe the Commission’s constitutional function and authority under WASH. CONST. art. IV, § 31. The case situates the Commission as the investigative and fact-finding body, with the Supreme Court retaining exclusive authority to impose suspension/removal/retirement when recommended.
  • In re Disciplinary Proc. Against Anderson, 138 Wn.2d 830 (1999)
    Role in the opinion: Cited for the court’s de novo review standard and the concept that the court is not bound by the Commission’s findings, while still giving “considerable weight” to credibility determinations. Later, it is used substantively as a removal precedent where a judge’s dishonest conduct (including misrepresentations on disclosure filings) demonstrated unfitness.
  • In re Disciplinary Proc. Against Turco, 137 Wn.2d 227 (1999)
    Role in the opinion: Provides (a) the de novo framework (independent evaluation of the record without a new evidentiary hearing), and (b) the “articulable nexus” principle—misconduct must bear a meaningful connection to judicial duties/fitness, even when occurring outside formal courtroom adjudication.
  • In re Disciplinary Proc. Against Deming, 108 Wn.2d 82 (1987)
    Role in the opinion: (a) Supports deference to the Commission’s credibility findings because the Commission observes demeanor; and (b) supplies the foundational Deming factors used to determine sanction severity. The court also notes that dishonesty during the discipline process can be considered within the Deming-factor sanction analysis.
  • In re Disciplinary Proc. Against Keenan, 199 Wn.2d 87 (2022)
    Role in the opinion: Central to interpreting CJC 1.3’s use of “abuse.” The court draws from Keenan’s explanation that “abuse” means “to misuse” (quoting Black’s Law Dictionary) and that the terminology change from “lend” to “abuse” was intended to reduce confusion and avoid sweeping in benign conduct (e.g., ordinary recommendations) while still capturing misuse of judicial prestige for advantage.
  • In re Disciplinary Proc. Against Eiler, 169 Wn.2d 340 (2010)
    Role in the opinion: Reinforces that sanction is determined by an independent evaluation of Deming factors and recognizes the Commission’s procedural elaboration in CJCRP 6(c). Also used for the proposition that long tenure aggravates misconduct because experienced judges “should know better.”
  • In re Disciplinary Proc. Against Flood, 5 Wn.3d 673 (2025)
    Role in the opinion: Supplies a limiting principle for removal: the court “recently held removal is limited to flagrant and intentional violations of the oath of office or misuse of power.” Flood also informs the court’s treatment of “cooperation”—defending oneself is not noncooperation, but dishonesty and disparagement during proceedings may aggravate sanction analysis.
  • In re Disciplinary Proc. Against Ritchie, 123 Wn.2d 725 (1994)
    Role in the opinion: A comparison point for removal based on dishonesty for personal gain (misrepresentations in reimbursement requests), demonstrating that deceitful conduct—even outside courtroom decision-making—can warrant removal because it is incompatible with judicial office.
  • In re Disciplinary Proc. Against Hammermaster, 139 Wn.2d 211 (1999)
    Role in the opinion: Supports the aggravating nature of failing to acknowledge impropriety; admission of actions does not necessarily equal recognition of their ethical gravity.

3.2. Legal Reasoning

A. Standard of review and proof

The court reaffirmed the discipline framework: Commission fact-finding must be proved by clear, cogent, and convincing evidence; the Supreme Court reviews Commission decisions de novo, meaning it independently evaluates whether the CJC was violated and what sanction is warranted, while giving “considerable weight” to the Commission’s credibility determinations because the Commission directly observed witnesses. This is a hybrid model—independent appellate judgment grounded in a deferential posture toward live credibility findings.

B. CJC 1.1 and 1.2: impropriety and integrity

The court treated CJC 1.1 and 1.2 as essentially established by undisputed facts. Ruzumna admitted he used the court seal and another judge’s signature stamp without permission to create a document to obtain a parking discount. That conduct, the court held, is an impropriety and reflects a lack of integrity, violating CJC 1.2 and thereby “necessarily” implicating CJC 1.1.

Notably, the court emphasized that calling the document “fraudulent” did not import criminal law elements or a criminal burden of proof. The disciplinary focus was ethical: deceitful or misleading conduct that undermines confidence in the judiciary.

C. Dishonesty during proceedings as aggravation

The Commission found, and the court agreed, that Ruzumna attempted to minimize or excuse his actions by fabricating a “convoluted story” that the document contained “multiple random stamps” and was merely a joke. Credibility findings (including testimony from the garage manager and HR director’s measurements showing insufficient space for additional stamps) supported the conclusion that the “joke” explanation was not truthful.

The court drew a careful line: “lying or not testifying truthfully” in the discipline case is “not itself a violation,” but it compounds the underlying impropriety and becomes relevant to sanction analysis (i.e., it signals character and fitness concerns and erodes trust).

D. CJC 1.3: “abuse” of prestige without an express knowledge requirement

The most precedent-setting portion of the opinion concerns CJC 1.3. A panel member suggested the rule typically targets benefits the judge “knows they are not entitled” to receive. The court rejected a knowledge/entitlement limitation, relying on In re Disciplinary Proc. Against Keenan to focus on the meaning of “abuse” as “misuse” or a “departure from reasonable use.”

Applying that standard, the court concluded that the unauthorized use of a sitting judge’s signature stamp and a court seal—tools imbued with official legal significance—constitutes an unreasonable and wrongful misuse of judicial prestige for personal economic benefit. Critically, the court held it did not need to decide whether Ruzumna reasonably believed he was entitled to the discount:

  • If he was not entitled, the conduct is a straightforward attempt to leverage judicial indicia to obtain an improper benefit.
  • If he was entitled, using misappropriated judicial insignia is still an unreasonable method that abuses the prestige of office, especially because legitimate channels (HR or court administration confirmation) were available.

The court also treated intent as practically evident: if the discount had been granted, Ruzumna “presumably would have accepted” it. That practical inference reinforced the conclusion that this was not a harmless joke but a bid for favorable treatment.

E. Sanction: Deming factors, CJCRP 6(c), and the Flood limitation on removal

On sanction, the court conducted an “independent evaluation” of the Deming factors (as recognized in In re Disciplinary Proc. Against Eiler) and the Commission’s codified elaboration in CJCRP 6(c), including an additional factor the court highlighted as especially important after In re Disciplinary Proc. Against Flood: whether the judge flagrantly and intentionally violated the oath of office.

The court characterized Ruzumna’s conduct as flagrant and intentional misuse of judicial power: it required deliberate, multi-step preparation (creating a dated document; accessing and applying the signature stamp; changing the stamp date; affixing the court seal) and exploited access gained through judicial service. That finding aligned the case with Flood’s removal threshold.

The court then weighed aggravating and mitigating considerations:

  • Aggravating: seriousness of misusing judicial insignia; inherent power differential between a judge and a parking attendant; misconduct occurred while serving as pro tem (strong nexus to duties per In re Disciplinary Proc. Against Turco); lack of genuine accountability (drawing from In re Disciplinary Proc. Against Hammermaster); long service as a pro tem (drawing from In re Disciplinary Proc. Against Eiler); ongoing dishonesty and disparagement during/post proceedings.
  • Mitigating: no prior complaints; evidence of positive reputation and community service.

Comparing to removal precedents involving dishonesty—In re Disciplinary Proc. Against Ritchie and In re Disciplinary Proc. Against Anderson— the court emphasized that removal has been warranted even when dishonesty was not committed while adjudicating from the bench. Here, the court found the case more severe: the dishonesty coincided with an abuse of judicial indicia enabled by judicial access.

3.3. Impact

The decision is likely to shape Washington judicial-discipline law in four practical ways:

  1. CJC 1.3 clarified for “official insignia” misuse: The opinion signals that misappropriating a judge’s signature stamp or a court seal for personal advantage is paradigmatic “abuse,” even if the benefit sought is small and even if the judge claims entitlement to the underlying benefit.
  2. Removal threshold operationalized post-Flood: By explicitly tying removal to “flagrant and intentional misuse of judicial power,” the court illustrates how Flood’s limiting principle applies to conduct outside the courtroom but connected to judicial access and authority.
  3. Process dishonesty as sanction accelerant: While not a standalone CJC violation, untruthful testimony and narrative-shifting during proceedings can meaningfully aggravate sanction outcomes because they evidence diminished integrity and irreparable trust damage.
  4. Deterrence around administrative “petty” benefits: The court rejects any “de minimis” framing. Using the machinery of the judiciary for mundane personal benefits (parking, discounts, customer-service concessions) is treated as a high-stakes threat to institutional legitimacy.

4. Complex Concepts Simplified

  • De novo review (in discipline cases): The Supreme Court independently decides whether the rules were violated and what sanction applies, but it still gives significant weight to the Commission’s firsthand credibility assessments.
  • Clear, cogent, and convincing evidence: A heightened civil standard—more demanding than “more likely than not,” less than “beyond a reasonable doubt.” It reflects the seriousness of disciplining or removing a judge.
  • “Abuse of the prestige of judicial office” (CJC 1.3): Not every reference to being a judge is prohibited. The rule targets misuse—leveraging judicial status, symbols, or authority to gain personal/economic advantage or special treatment.
  • Articulable nexus: Even if conduct occurs outside the courtroom, discipline requires a meaningful connection to judicial duties or fitness. Here, access to official stamps and the integrity expectations attached to judicial status created a direct nexus.
  • Deming factors / CJCRP 6(c): Structured considerations used to calibrate sanctions (pattern vs. isolated act, harm, intent, acknowledgment, reputation, impact on public confidence, misuse of position, etc.).

5. Conclusion

In re Disciplinary Proc. Against Ruzumna reinforces a bright ethical boundary: official judicial insignia are not tools for personal errands. The court held that misappropriating a judge’s signature stamp and a court seal to obtain a personal benefit constitutes violations of CJC 1.1 and 1.2 and, under CJC 1.3, an “abuse” because it is a departure from reasonable use of judicial prestige—regardless of claims of entitlement or humor.

By affirming censure and removal, the decision underscores that integrity-based misconduct involving deception and misuse of judicial symbols can satisfy the post-Flood removal standard as a flagrant and intentional misuse of judicial power, especially when compounded by dishonesty during disciplinary proceedings.