In considering this issue, the referee's findings of fact and conclusions of law are deemed conclusive because neither party ordered a transcript of the proceedings. Rule 14(e), Rules on Lawyers Professional Responsibility (RLPR); In re Fru , 829 N.W.2d 379, 387 (Minn. 2013).

We have emphasized that misconduct in representation of clients in immigration matters has "potentially grave consequences." In re Fru , 829 N.W.2d 379, 388-89 (Minn. 2013).

A referee's findings and conclusions are deemed conclusive when neither party orders a transcript of the proceeding. Rule 14(e), Rules on Lawyers Professional Responsibility (RLPR); seeIn re Fru , 829 N.W.2d 379, 387 (Minn. 2013). We review a referee's findings and conclusions for clear error when a party orders a transcript.

We have held that such misconduct has "potentially grave consequences" and can put clients at "risk for deportation or removal." In re Fru , 829 N.W.2d 379, 388–89 (Minn. 2013). We have suspended and disbarred lawyers for such misconduct.

Individuals with uncertain legal status in this country facing removal or deportation are particularly vulnerable and that vulnerability can be an aggravating factor. SeeIn re Fru , 829 N.W.2d 379, 391 (Minn. 2013) (stating that "[w]e are particularly troubled by the fact that Fru's misconduct threatened the immigration status of many of his clients" and that those clients were "vulnerable and depended on him to guide them through the complex—and often punitive—maze of federal immigration law" (citation omitted) (internal quotation marks omitted)); In re Kaszynski , 620 N.W.2d 708, 714 (Minn. 2001)

When determining the appropriate discipline, we are guided by four factors: “(1) the nature of the misconduct; (2) the cumulative weight of the disciplinary violations; (3) the harm to the public; and (4) the harm to the legal profession.” Id. at 628–29 (quoting In re Fru, 829 N.W.2d 379, 388 (Minn.2013)). We also consider any aggravating or mitigating factors.

Because neither party ordered a transcript of the proceedings, the referee's findings and conclusions are conclusive under Rule 14(e), RLPR. In re Fru, 829 N.W.2d 379, 387 (Minn.2013).

This type of misconduct warrants severe discipline. See In re Fru, 829 N.W.2d 379, 388 (Minn.2013) (“We have said that ‘[a] continuing pattern of client neglect is serious misconduct often warranting indefinite suspension by itself....’ ”) (quoting In re Rhodes, 740 N.W.2d 574, 578 (Minn.2007)); In re Grzybek, 567 N.W.2d 259, 263 (Minn.1997) (“Repeated neglect of client matters, misrepresentations, and failure to communicate with clients typically warrant indefinite suspension.”).

Were it not for the mitigating factors present, a longer suspension would be appropriate in this case. See In re Lennington, 948 N.W.2d 685, 685-86 (Minn. 2020) (order) (suspending a lawyer for six months for professional misconduct in eight client matters, including neglect, failing to communicate, failure to clarify a fee, failure to deposit funds in trust, failing to refund or timely refund unearned fees, charging an unreasonable fee, failing to return documents to clients, and noncooperation in disciplinary investigations without referencing any mitigating factors); In re Fru, 829 N.W.2d 379, 381-87 (Minn. 2013) (suspending a lawyer for two years for a pattern of incompetence, client neglect, and noncommunication in seven matters; failing to deposit client fees in trust; failing to timely refund an unearned, advance fee to one client; false statements to several of these clients; and noncooperation in a disciplinary investigation and stating that "[t]he referee found no mitigating circumstances").

Finally, we consider "other disciplinary rule violations" more severely when paired with "serious client neglect and incompetence." In re Fru, 829 N.W.2d 379, 389 (Minn. 2013); In re Udeani, 984 N.W.2d 550, 553 (Minn. 2023). Padden's other disciplinary rule violations include (1) the failure to appear at a hearing in the S.Y.I. matter, resulting in the issuance of a bench warrant for S.Y.I.'s arrest; (2) the failure to timely appear for S.M.K.'s pretrial hearing without notice to the court or prosecution; (3) the failure to appear for Q.D.C.'s sentencing without notice to the court or prosecution; (4) the failure