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Christman v. People
367 P.3d 1204
Colo.
2016
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Background

  • Andrea Christman was admitted to the Colorado bar in 2010 and immediately suspended by court order; she stipulated to a one-year-and-one-day suspension in 2014 for misconduct in six client matters.
  • Misconduct included failures of competence, diligence, communication, withdrawal, and trust-account supervision across family-law, real-property, and civil-defense matters resulting in prejudice to clients (default judgment, improper partition decree, uncompleted PERA transfer, unresolved child-support issues).
  • She moved to New Mexico, worked as an associate then as an administrative law judge (ALJ), and was reciprocally suspended in New Mexico; she seeks reinstatement in Colorado in 2015 and testified pro se at the hearing.
  • At the reinstatement hearing she relied on her ALJ experience, CLE coursework, community service, and personal remediation but provided no documentary corroboration, witness affidavits, or prehearing brief and missed several procedural deadlines.
  • The Hearing Board found she complied with the technical disciplinary requirements and paid costs, but her unsupported testimony failed to prove fitness to practice or clear-and-convincing evidence of rehabilitation.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Compliance with disciplinary orders and rules Christman contended she complied with orders and paid costs People agreed she met technical rule compliance Board found technical compliance satisfied
Fitness to practice law Christman argued ALJ experience and CLEs show current competence People argued testimony alone insufficient without corroboration Denied — testimony insufficient to prove fitness by clear and convincing evidence
Rehabilitation / change in character Christman pointed to counseling, community service, steady employment, and claimed lessons learned People emphasized lack of corroborating witnesses, failure to accept full responsibility, and continued patterns of inattention Denied — no clear-and-convincing proof of rehabilitation; risk of recurrence remains
Presentation and procedural diligence at hearing Christman argued pro se appearance and scheduling constraints justified limited evidence People stressed omissions undermined credibility; Board noted missed filings and lack of exhibits/witnesses Held against Christman — poor presentation reinforced doubts and contributed to denial

Key Cases Cited

  • In re Price, 18 P.3d 185 (Colo. 2001) (reinstatement requires clear-and-convincing proof of compliance, fitness, and rehabilitation)
  • People v. Klein, 756 P.2d 1013 (Colo. 1988) (factors for assessing rehabilitation and likelihood of recurrence)
  • In re Cantrell, 785 P.2d 312 (Okla. 1989) (reinstatement standards and burden of proof discussion)
  • In re Sharpe, 499 P.2d 406 (Okla. 1972) (rehabilitation and reinstatement principles)
  • Tardiff v. State Bar, 612 P.2d 919 (Cal. 1980) (consideration of petitioner’s character relative to original shortcomings)
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Case Details

Case Name: Christman v. People
Court Name: Supreme Court of Colorado
Date Published: Feb 10, 2016
Citation: 367 P.3d 1204
Docket Number: No. 15PDJ063
Court Abbreviation: Colo.