STATE ex rel. OKLAHOMA BAR ASSOCIATION v. KNIGHT, 2014 OK 71

David W. Knight, admitted in Oklahoma (1982) and Texas, was placed on a one-year probated suspension in Texas by Agreed Judgment dated Oct. 10, 2013, for client neglect, failing to communicate, and failing to surrender client papers. The probated period ran Nov. 1, 2013–Oct. 31, 2014.
The Oklahoma Bar Association (OBA) transmitted the Texas disciplinary documentation under RGDP Rule 7.7, and this Court ordered Knight to show cause; Knight did not respond.
The Texas findings constituted prima facie evidence under RGDP 7.7(b); Knight bore the burden to rebut but did not do so.
The Court identified the Texas violations as equivalent to violations of Oklahoma Rules: competence, diligence, communication, surrendering client property, and expediting litigation (ORPC Rules 1.1, 1.3, 1.4(a)(3)-(4), 1.16(d), 3.2).
Knight had prior discipline: a 2009 Texas partially probated suspension for similar misconduct which resulted in a final order and led to an OBA Professional Responsibility Commission private reprimand for failing to report; Knight failed to notify the OBA of the 2013 Texas discipline within 20 days as required by RGDP 7.7(a).
Based on the current Texas suspension, Knight's disciplinary history, and his failure to respond and to report, the Oklahoma Supreme Court imposed a one-year suspension in Oklahoma and ordered the OBA to notify Texas authorities.

Issue	Complainant's Argument (OBA)	Respondent's Argument (Knight)	Held
Whether Texas final discipline is prima facie evidence warranting reciprocal discipline in OK	Texas Agreed Judgment proves neglect, communication failures, and failure to surrender client property; warrants discipline here	(No response filed)	Texas findings are prima facie evidence; Knight failed to rebut; violations mapped to ORPC and support discipline.
Whether Knight violated Oklahoma reporting rule (RGDP 7.7(a))	Knight failed to notify OBA within 20 days of final Texas order; failure itself is disciplinable	(No response filed)	Failure to report is a separate violation and aggravating factor for discipline.
Appropriate severity of discipline given prior misconduct	Prior 2009 Texas discipline and OBA reprimand show pattern; one-year suspension in Oklahoma is appropriate to protect public and deter	(No response filed)	One-year suspension ordered, citing prior similar sanctions and lack of remediation.
Whether OBA procedure in prior filing (Rule 6 v. Rule 7.7) affects treatment of Knight's earlier 2009 discipline	OBA previously used Rule 6 for 2009 Texas matter which allowed PRC reprimand; Rule 7.7 would produce different procedural outcomes; OBA should follow Rule 7.7 for transmissions	(Not argued by Knight)	Court admonishes OBA to use Rule 7.7 transmissions for out-of-state final discipline to ensure consistent treatment, but does not bar use of Rule 6 in appropriate circumstances.

State ex rel. Okla. Bar Ass'n v. Benefield, 125 P.3d 1191 (2005 OK 75) (one-year suspension appropriate for pattern of client neglect and communication failures)
State ex rel. Okla. Bar Ass'n v. Rennie, 945 P.2d 494 (1997 OK 108) (one-year suspension where attorney previously disciplined and failed to respond to grievance)
State ex rel. Okla. Bar Ass'n v. Patterson, 28 P.3d 551 (2001 OK 51) (reciprocal discipline standard; Court may impose same, greater, or lesser discipline)
State ex rel. Okla. Bar Ass'n v. Kleinsmith, 297 P.3d 1248 (2013 OK 16) (Court's discretion in reciprocal proceedings to vary discipline)
State ex rel. Okla. Bar Ass'n v. Whitebook, 242 P.3d 517 (2010 OK 72) (failure to respect Court authority and nonresponse can justify increased discipline)
State ex rel. Okla. Bar Ass'n v. Zannotti, 326 P.3d 496 (2014 OK 25) (OBA must transmit out-of-state discipline documents under Rule 7 procedures to avoid inconsistent outcomes)
State ex rel. Okla. Bar Ass'n v. Henderson, 977 P.2d 1096 (1999 OK 29) (burden on disciplined attorney to rebut prima facie evidence from other jurisdiction)