In re Nwaneri, 912 N.W.2d 882

Patrick C. Nwaneri was suspended on June 7, 2017 for a minimum of 30 days and required to show proof of passing the MPRE by June 7, 2018; failure to do so would result in automatic re-suspension under Rule 18(e)(3), RLPR.
The court conditionally reinstated Nwaneri on July 21, 2017 while reiterating the MPRE proof deadline and the automatic-suspension consequence for noncompliance.
Nwaneri failed to file proof of a passing MPRE score by June 7, 2018; he had taken the MPRE in August 2017 and March 2018 and failed both attempts.
On May 22, 2018 Nwaneri moved for an extension until November 1, 2018 to provide proof, citing family travel and a sentencing hearing that interfered with preparation and testing.
The Director of the Office of Lawyers Professional Responsibility opposed the extension; the court reviewed precedent denying similar extension requests and found Nwaneri had not shown good cause.
The court denied the extension, revoked conditional reinstatement, ordered an indefinite suspension effective 10 days from the order, and set reinstatement procedures tied to passing the MPRE under Rule 18(f), RLPR.

Issue	Nwaneri's Argument	Director's Argument	Held
Whether good cause existed to extend the MPRE proof deadline	Family obligations and a sentencing hearing prevented adequate preparation and timely passing	No good cause; deadline must be enforced	Denied; no good cause shown
Whether failure to timely show MPRE passage triggers automatic re-suspension	Nwaneri sought extension to avoid suspension	Automatic re-suspension applies per Rule 18(e)(3) absent waiver	Conditional reinstatement revoked; indefinite suspension imposed
Whether a speedy hearing on the extension motion was required	Requested speedy hearing	Opposed or not shown necessary	Motion for speedy hearing denied as moot
Scope of remedial step for noncompliance (reinstatement procedure)	Sought more time rather than restart procedure	Reinstatement allowed only after proof of MPRE passage per Rule 18(f)	May apply for reinstatement under Rule 18(f) after passing MPRE

In re Nwaneri, 896 N.W.2d 518 (Minn. 2017) (initial suspension and MPRE proof requirement)
In re Nwaneri, 899 N.W.2d 185 (Minn. 2017) (order conditionally reinstating and reiterating MPRE deadline)
In re Swanson, 877 N.W.2d 190 (Minn. 2016) (denying extension for MPRE deadline excuses)
In re McCormick, 837 N.W.2d 493 (Minn. 2013) (denying extension where attorney failed MPRE due to illness)
In re Ruhland, 833 N.W.2d 401 (Minn. 2013) (denying extension where personal-care obligations caused registration failure)

BY THE COURT: David L. Lillehaug