In re Reinstatement of Mose, 843 N.W.2d 570

William G. Mose admitted 1980; solo practice 1984–1990; disciplinary proceedings beginning 1989 for incompetence, client neglect, and failing to follow court orders.
1989: public reprimand and two-year probation; ordered to take trial advocacy course and pay restitution to two clients.
1990–1991: probation revoked and indefinitely suspended after additional misconduct; reinstatement conditioned on compliance with prior orders including completion of a 4- or 8-day trial advocacy skills course (Minnesota Advocacy Institute or Director-approved equivalent).
2007: first petition for reinstatement denied (Mose IV) for failure to show moral change, compliance, and competence.
2012: second petition for reinstatement heard by LPRB panel, which recommended denial because Mose had not completed the required trial advocacy course, failed to demonstrate moral change, and lacked intellectual competence; Court adopts panel recommendation and denies petition.

Issue	Plaintiff's Argument (Mose)	Defendant's Argument (Director/Panel)	Held
Compliance with reinstatement conditions	Mose argued he satisfied conditions; substituted CLE/webcast lecture for required trial advocacy course	Panel/Director: Mose did not seek Director approval; webcast/lecture lack active trial participation required	Held: Mose failed to satisfy the trial advocacy-course requirement
Moral change	Mose pointed to volunteer work (HOME Line, FCS, special-education student teaching) as evidence of remorse and changed conduct	Panel: Volunteer work was limited or showed same problems (lack of independence, failure to follow through); Mose delayed paying restitution; no plan to prevent recurrence	Held: Mose did not prove the requisite moral change by clear and convincing evidence
Intellectual competence to practice law	Mose cited passing the bar multiple times and current CLE compliance	Panel: Passing bar and CLE insufficient after long absence; volunteer work did not demonstrate legal reasoning, case management, or substantive legal work	Held: Mose lacks demonstrated intellectual competence
Burden and standard of review	Mose challenged panel findings	Director/Panel: factual findings supported; court defers to credibility where transcript ordered but independently reviews record	Held: Court independently reviews but upholds panel findings as supported by record

In re Mose, 443 N.W.2d 191 (Minn. 1989) (public reprimand and probation; trial-advocacy course and restitution conditions)
In re Mose, 458 N.W.2d 100 (Minn. 1990) (probation revoked and indefinite suspension)
In re Mose, 470 N.W.2d 109 (Minn. 1991) (indefinite suspension conditioned on full compliance with prior orders)
In re Mose, 754 N.W.2d 357 (Minn. 2008) (prior petition for reinstatement denied; standards for moral change and competence)
In re Kadrie, 602 N.W.2d 868 (Minn. 1999) (court’s responsibility to decide reinstatement)
In re Singer, 735 N.W.2d 698 (Minn. 2007) (independent review of reinstatement record)
In re Anderley, 696 N.W.2d 380 (Minn. 2005) (standard: clear and convincing evidence of moral change)
In re Reutter, 474 N.W.2d 343 (Minn. 1991) (moral change as principal factor for reinstatement)
In re Lieber, 834 N.W.2d 200 (Minn. 2013) (demonstrated post-suspension conduct can show moral change)
In re Swanson, 405 N.W.2d 892 (Minn. 1987) (denial where petitioner did not accept responsibility)
In re Ramirez, 719 N.W.2d 920 (Minn. 2006) (work involving legal research/case administration supports competence)