In Re Complaint as to the Conduct of Lawrence, 256 P.3d 1070

In 2007, the accused represented a juvenile male in a delinquency case involving alleged acts at a middle school.
During a second detention hearing, the accused called two victims who testified the acts were not sexual but horseplay; victims felt pressure to portray harm.
The hearing was open to the press; after the hearing, the accused obtained the official audio and prepared a partial transcript of the victims' testimony.
A reporter later contacted the accused; he released the partial transcript to the reporter without obtaining the court's consent.
Judge Collins learned of the release, met with the accused and a deputy DA, and told them to release no further transcripts; accounts of the meeting differ.
The Bar charged the accused with violating ORS 419A.255 and RPC 8.4(a)(4); the trial panel suspended him for 60 days; this court reviews de novo and dismisses the complaint for lack of clear and convincing prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether release violated ORS 419A.255 and RPC 8.4(a)(4).	Lawrence	Lawrence	No clear and convincing prejudice shown.
Whether the information released was part of the record and subject to juvenile confidentiality.	Bar	Lawrence	Assumed improper action; not dispositive for prejudice.
Whether the release caused prejudice to the administration of justice.	Bar	Lawrence	Prejudice not shown; harm not established.

In re Kluge, 335 Or. 326 (Oregon Supreme Court, 2003) (prejudice requires actual or substantial potential harm; single act must be substantial)
In re Haws, 310 Or. 741 (Oregon Supreme Court, 1990) (two components of administration of justice; prejudice can affect procedure or substantive rights)
In re Eadie, 333 Or. 42 (Oregon Supreme Court, 2001) (misrepresentation to influence court can cause substantial harm to procedural functioning)
In re Morris, 326 Or. 493 (Oregon Supreme Court, 1998) (single act with potential to cause substantial harm when altering filings)
In re Thompson, 325 Or. 467 (Oregon Supreme Court, 1997) (ex parte conduct by a lawyer can create substantial harm to justice interests)