History
  • No items yet
midpage
In re Ruffin
54 So. 3d 645
| La. | 2011
Read the full case

Background

  • 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)
Read the full case

Case Details

Case Name: In re Ruffin
Court Name: Supreme Court of Louisiana
Date Published: Jan 14, 2011
Citation: 54 So. 3d 645
Docket Number: No. 2010-B-2544
Court Abbreviation: La.