In re Disciplinary Action Against Hawkins, 834 N.W.2d 663

Hawkins was admitted in TX, MN, AZ, and ND; TX filed a disciplinary petition in 1997 for misconduct in a criminal matter.
TX district court suspended Hawkins for 1 year and placed him on 3 years of probation, plus $15,000 in fees and 15 hours per month of pro bono service.
Texas found Hawkins failed to communicate with D.S., failed to continue representation, and failed to protect D.S.'s interests; he sent improper letters and failed to attend hearings.
Hawkins later did not comply with suspension/probation terms, leading to a 2003 Texas disbarment for noncompliance.
ND and AZ imposed reciprocal discipline (ND: 1-year suspension + 3 years probation; AZ: 1-year suspension + 2 years probation) while Hawkins did not notify the Minnesota Director of disciplinary actions; the Director investigated but Hawkins provided no cooperation.
Minnesota suspended Hawkins under Rule 12(c) RLPR and ultimately disbarred him after determining Texas proceedings were fair and the discipline, though perhaps different in Minnesota, was not unjust.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reciprocal discipline should be imposed based on Texas disbarment.	Director: Texas proceedings were fair and the Texas disbarment is warranted; discipline would not be unjust or substantially different from Minnesota.	Hawkins argues against reciprocal discipline (non-cooperation, notice issues, or differences in Minnesota process).	Yes; the court imposed reciprocal disbarment in Minnesota.

In re Wolff, 810 N.W.2d 312 (Minn. 2012) (basis for considering procedural fairness and reciprocity in discipline)
In re Roff, 581 N.W.2d 32 (Minn. 1998) (notice and opportunity to be heard suffice for fairness)
In re Morin, 469 N.W.2d 714 (Minn. 1991) (availability of mitigation/character evidence supports fairness analysis)
In re Daly, 291 Minn. 488, 189 N.W.2d 176 (Minn. 1971) (willful disobedience can justify disbarment)
In re Grzybek, 567 N.W.2d 259 (Minn. 1997) (disbarment for repeated failure to comply with court orders)