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In re Ryan
97 Wn. 2d 284 (Wash. 1982)4 Citing cases
Neravetla v. Dep't of Health
198 Wn. App. 647 (Wash. Ct. App. 2017) Cited 6 timesHaley , 117 Wash.2d at 743, 818 P.2d 1062. ¶36 In In re Ryan , 97 Wash.2d 284, 287, 644 P.2d 675 (1982), Ryan challenged the discipline rules for the Washington State Bar Association, and argued that the terms "mental illness or other mental incapacity" were too vague to withstand constitutional challenge. In rejecting his argument, the court upheld the rules because "the mental condition must cause the attorney to be unable to conduct his/her law practice adequately....
Neravetla v. Dep't of Health
394 P.3d 1028 (Wash. Ct. App. 2017)Haley , 117 Wash.2d at 743, 818 P.2d 1062. ¶36 In In re Ryan , 97 Wash.2d 284, 287, 644 P.2d 675 (1982), Ryan challenged the discipline rules for the Washington State Bar Association, and argued that the terms "mental illness or other mental incapacity" were too vague to withstand constitutional challenge. In rejecting his argument, the court upheld the rules because "the mental condition must cause the attorney to be unable to conduct his/her law practice adequately....
In re Keefe
159 Wn. 2d 822 (Wash. 2007) Cited 5 timesHolding that "an in-person evaluation ... may have strengthened [the expert's] testimony," but the evidence rules do not "require such firsthand knowledge"
See, e.g., In re Disciplinary Proceeding Against Meade, 103 Wn.2d 374, 379-80, 693 P.2d 713 (1985); In re Disciplinary Proceeding Against Ryan, 97 Wn.2d 284, 287, 644 P.2d 675 (1982); In re Campbell, 74 Wn.2d 276, 280-81, 444 P.2d 784 (1968). In Meade, the psychiatrist testified that Meade "was competent to handle most legal matters" and "may have appeared competent at the earlier proceedings because his appearance and verbal abilities were unaffected."
Disability of Diamondstone
153 Wn. 2d 430 (Wash. 2005) Cited 11 timesExplaining that "[t]he hearing officer is a lawyer and is therefore able to use this information to form a conclusion as to [an attorney's] capacity to practice law" (citing In re Disciplinary Proceeding Against Brown, 94 Wn. App. 7, 13-14, 972 R2d 101 (1998) (recognizing that members of the dental disciplinary board could use their "experience and specialized knowledge to evaluate and draw inferences from the evidence when finding unprofessional conduct"))
¶16 Washington cases involving the transfer of an attorney to disability inactive status do not articulate a specific standard of review. See In re Disciplinary Proceeding Against Meade, 103 Wn.2d 374, 378, 693 P.2d 713 (1985); In re Disciplinary Proceeding Against Ryan, 97 Wn.2d 284, 286-87, 644 P.2d 675 (1982); In re Matter of Campbell, 74 Wn.2d 276, 278-79, 444 P.2d 784 (1968). However, the procedure for appealing an order of transfer to inactive status is the same as the procedure for appealing suspensions.