In Re the Reciprocal Discipline of Walton, 287 P.3d 1098

Walton is Oregon-licensed, Hawai‘i-admitted attorney (BR 3.5).
Hawai‘i Disciplinary Counsel disciplined Walton for 14 months of unauthorized use of OSP Westlaw passwords, paid by Palau, for personal legal research.
Hawai‘i Supreme Court imposed a public reprimand; Oregon Bar sought six-month suspension.
Oregon Bar based its request on RPC 8.4(a)(3) (dishonesty) and potentially RPC 8.4(a)(2) (criminal act), arguing dishonesty affected fitness to practice.
Oregon Supreme Court concluded Walton’s conduct violated RPC 8.4(a)(3) and (1); no serious injury or proven criminal act occurred; public reprimand appropriate under ABA Standards 5.13.
Court relied on Hawai‘i stipulation, Bar response, and prior Oregon precedents to determine sanction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Oregon should suspend Walton or reprimand	Bar urged six-month suspension	Walton argued for private/private reprimand; Hawai‘i had public reprimand	Public reprimand appropriate
Whether Walton’s conduct violated RPC 8.4(a)(3) and (1)	Bar: dishonesty violated 8.4(a)(3) and 8.4(a)(1)	Walton admitted use; no personal gain; no criminal act proven	Walton violated 8.4(a)(3) and (1)
Whether Bar proved a criminal act under Hawai‘i statutes	Bar claimed Hawai‘i criminal acts occurred	No Hawaii conviction; statutes not clearly applicable	Criminal act not proven; 8.4(a)(2) not established
Applicability of ABA Standards to sanction	Bar sought suspension; Standards 5.11/5.12/5.13 guide sanction	Public reprimand warranted under Standards 5.13	Mitigating factors outweigh aggravating; reprimand proper

In re Lopez, 350 Or 192 (2011) (guides use of ABA Standards; recognizes court autonomy in sanctioning reciprocal discipline)
In re Flannery, 334 Or 224 (2002) (reprimand appropriate when conduct does not seriously reflect on fitness)
In re Carpenter, 337 Or 226 (2004) (public reprimand for intentional misconduct not involving recurrence or criminality)