In re Disciplinary Action Against Jaeger, 834 N.W.2d 705

Hugh D. Jaeger, admitted to practice in Minnesota (1977) and before the USPTO (1974), was suspended for 120 days on August 11, 2011, with an express prohibition on practicing before the USPTO and a Rule 26 notice requirement.
Despite the suspension, between September 2011 and March 2012 Jaeger represented clients in nine USPTO trademark and patent matters, filed documents, used attorney letterhead, and identified himself as counsel and correspondence recipient.
Jaeger provided an affidavit claiming client notice of suspension but did not supply notice letters or certified-mail proof as required by Rule 26(e), RLPR.
Jaeger repeatedly failed to respond to multiple Director investigations and to provide requested information regarding hiring a law clerk while suspended, unauthorized practice, and complaints from the USPTO and an individual.
The Director filed a petition for disciplinary action (served June 28, 2012); Jaeger did not answer, so the allegations were deemed admitted under Rule 13(b), RLPR. The Director sought disbarment; Jaeger did not participate in the disciplinary proceedings or oral argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Unauthorized practice of law after suspension	Jaeger continued to practice before the USPTO in multiple matters despite court order prohibiting practice; this is dishonest and contemptuous conduct warranting severe discipline	Jaeger did not contest allegations (no substantive defense)	Court deemed allegations admitted and held Jaeger engaged in unauthorized practice and contempt of court
Failure to provide Rule 26 notice proof to clients	Jaeger failed to produce required notice letters or certified-mail proof despite an affidavit claiming notice	Jaeger offered no evidentiary proof or response	Court held Jaeger failed to comply with Rule 26(e) and that failure is a separate ground for discipline
Failure to cooperate with disciplinary investigations	Director contends Jaeger ignored multiple investigation requests over months, aggravating misconduct	Jaeger did not respond or cooperate	Court found persistent noncooperation and treated it as aggravating misconduct increasing sanction severity
Appropriate discipline	Director requests disbarment given multiple, repeated violations and prior discipline	Jaeger offered no mitigating evidence or arguments; no appearance at proceedings	Court disbarred Jaeger, citing cumulative misconduct, prior discipline, lack of mitigation, and harm to public confidence

In re Jorissen, 391 N.W.2d 822 (Minn. 1986) (disbarment for practicing while suspended and misleading courts)
In re Ray, 452 N.W.2d 689 (Minn. 1990) (suspension continued rather than disbarment where clients were on notice and cooperation/mitigation present)
In re Ray, 610 N.W.2d 342 (Minn. 2000) (disbarment after repeated unauthorized-practice violations and failure to cooperate)
In re Grigsby, 815 N.W.2d 836 (Minn. 2012) (discipline for practicing while suspended; mitigation considered where single instance and client not harmed)
In re Nathanson, 812 N.W.2d 70 (Minn. 2012) (purpose of disciplinary sanctions: protect public, safeguard system, deter misconduct)
In re Lundeen, 811 N.W.2d 602 (Minn. 2012) (four-factor disciplinary analysis)
In re Rhodes, 740 N.W.2d 574 (Minn. 2007) (failure to cooperate is serious and aggravates discipline)
In re Swokowski, 796 N.W.2d 317 (Minn. 2011) (failure to comply with Rule 26 is grounds for discipline)