Office of Lawyer Regulation v. Bridget E. Boyle
850 N.W.2d 201
Wis.2014Background
- Bridget E. Boyle, admitted 1995, filed a petition under SCR 22.19 seeking consensual revocation of her Wisconsin law license because she cannot successfully defend numerous OLR investigations, a referee finding, and an OLR complaint alleging multiple counts of professional misconduct.
- Boyle has a lengthy disciplinary history: private reprimand (2008), a 60-day suspension (2012), disbarment from the Seventh Circuit (2012), and a six-month suspension effective January 30, 2014 (2013). Her Wisconsin license was suspended at the time of this petition.
- Attachments to the petition included the OLR’s summary of 14 investigative matters, a referee’s report finding 22 counts of misconduct in four matters (recommendation for 18-month suspension), and the OLR’s complaint alleging 15 counts in five matters (seeking one-year suspension).
- Alleged violations span competence, diligence, communication, fee and trust-account rules, conflicts, supervision, dishonesty, failure to cooperate with OLR investigations, and duties on suspension/revocation (numerous SCR provisions cited).
- Boyle agreed she could not defend the allegations, consented to revocation voluntarily and with opportunity to consult counsel, and agreed to specified restitution. The OLR supported revocation and proposed restitution and costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Boyle’s petition for consensual revocation under SCR 22.19 should be granted | Boyle: cannot successfully defend against pending allegations; seeks consensual revocation | OLR: supports petition based on record and attachments | Granted: court revoked Boyle’s license effective the date of the order |
| Effective date of revocation | Boyle: requested retroactive effect to Jan 30, 2014 (start of prior suspension) | OLR: endorsed retroactive date but court custom favors order date | Denied: revocation effective on date of this order (not retroactive) |
| Restitution to clients | Boyle: agreed to pay specified restitution amounts | OLR: requested restitution to specified former clients (and deferred on some matters) | Ordered: Boyle to pay $2,000 (J.T.), $10,000 (E.K.), $5,000 (D.H.), and any award from fee arbitration for L.W. within 60 days |
| Allocation of costs for disciplinary proceedings | OLR: requested full costs ($13,272.42 as of Feb 21, 2014) | Boyle: did not object or request reduction | Ordered: Boyle to pay full costs; restitution must be completed before paying costs |
Key Cases Cited
- In re Disciplinary Proceedings Against Boyle, 341 Wis. 2d 92, 813 N.W.2d 215 (Wis. 2012) (prior suspension for multiple ethical violations)
- In re Disciplinary Proceedings Against Boyle, 351 Wis. 2d 713, 840 N.W.2d 694 (Wis. 2013) (six-month suspension imposed; effective Jan. 30, 2014)
- In re Bridget Boyle-Saxton, 668 F.3d 471 (7th Cir. 2012) (disbarment from Seventh Circuit for client abandonment)
