In re Ruffin
54 So. 3d 645
| La. | 2011Background
- ODC filed formal charges against Tanzanika Q. Ruffin in 2009 alleging multiple Rule 8.4 violations.
- Facts were stipulated: Ruffin, then an Orleans Parish ADA, confronted Dwayne Anthony about a dishonored $375 check paid by his fiancée, using her status as an ADA.
- Ruffin presented herself with ADA credentials and warned of arrest/prosecution to collect the debt.
- Anthony disputed owing the debt; Ruffin’s conduct led to her termination from the DA’s office and disciplinary investigation.
- Hearing committee accepted the stipulation, found violations of Rule 8.4(a), (d), and (g), and recommended a public reprimand with mitigating factors.
- Disciplinary Board recommended a six-month suspension with all but 30 days deferred; the Supreme Court ultimately suspended Ruffin for six months with 30 days deferred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Ruffin violate Rules 8.4(a)/(d)/(g)? | ODC contends conduct violated these rules. | Ruffin argues mitigating factors reduce severity (implicit). | Yes; rules violated as stipulated and supported by record. |
| Is suspension the appropriate sanction given the misconduct? | Board's recommendation supports suspension; baseline sanction possible. | Mitigating factors justify lesser sanctions; possibly reprimand or deferred suspension. | Suspension warranted; six months with most of it deferred. |
Key Cases Cited
- Louisiana State Bar Ass'n v. Harrington, 585 So.2d 514 (La. 1990) (nine-month suspension for similar misconduct in dual roles)
- In re: Caillouet, 800 So.2d 367 (La. 2001) (CC/continuance sanction guiding suspension in related context)
- Louisiana State Bar Ass'n v. Reis, 513 So.2d 1173 (La. 1987) (discipline aims to protect public and deter misconduct)
- In re: Banks, 18 So.3d 57 (La. 2009) (manifest error standard for factual findings in discipline)
- In re: Pardue, 633 So.2d 150 (La. 1994) (standard for manifest error review)
