In re Jonas, 202 A.3d 1187

Edwin R. Jonas III sought reinstatement to the Maine Bar; a single justice denied his petition.
This appeal follows an earlier appeal in which the Court remanded for reconsideration under the “reasonable person” standard for admissibility (In re Jonas), noting some evidence may have been wrongly excluded under the Maine Rules of Evidence.
The remand was narrowly limited by the Court to: (1) evidence explicitly excluded under the Rules of Evidence in the original proceeding, and (2) evidence of post-trial events (reinstatement/discipline/further litigation) the single justice allowed.
On remand the single justice followed the Court’s mandate and considered the limited additional evidence; Jonas argued the limited scope denied him due process and that additional evidence would support reinstatement.
The single justice again denied reinstatement, finding Jonas failed to satisfy the clear-and-convincing reinstatement criteria; the Court affirmed, concluding the remand process and outcome were proper.

Issue	Plaintiff's Argument (Jonas)	Defendant's Argument (Single Justice/Board)	Held
Scope of remand and due process	Remand was too narrow; denied fair process to present all relevant evidence	Remand followed Court mandate; allowed limited additional evidence and mitigatory opportunity	Affirmed: limited remand did not violate due process under Mathews balancing
Standard for admissibility	Wanted broader admission of evidence excluded under Rules of Evidence	Court directed use of reasonable-person standard on remand, but limited scope per mandate	Affirmed: single justice complied with mandate; excluded evidence not within remand scope was properly not considered
Sufficiency of evidence for reinstatement	New and post-trial evidence would compel reinstatement	Single justice found new evidence added little and substantial contrary evidence remained	Affirmed: Jonas failed to meet clear-and-convincing burden under M. Bar R. 29(e)
Whether remand compelled different outcome	Jonas argued additional material should change result	Single justice assessed entire record including remand evidence and found original conclusions supported	Affirmed: record did not compel a different ruling

In re Edwin R. Jonas III, 164 A.3d 120 (Me. 2017) (clarified admissibility standard and limited scope of remand)
Greaton v. Greaton, 36 A.3d 913 (Me. 2012) (appellant must show actual error in judgment, not just procedural error)
Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (due-process balancing test for what process is required)
Fichter v. Bd. of Environmental Protection, 604 A.2d 433 (Me. 1992) (due process requirements are flexible and context-dependent)